At HOYA, we are committed to operating our business ethically and in compliance with all applicable laws, regulations, and policies. We believe that the key to maintaining integrity in all aspects of our operations is through the development and implementation of a robust compliance program.

Our compliance program is designed to ensure that we follow the highest standards of conduct, adhere to regulatory requirements, and operate ethically in our business practices. Our program is founded on our company values and is integrated into all aspects of our operations to ensure that we adhere to the highest standards of ethical and legal conduct.

Our compliance program is led by our Compliance Officer, who works alongside our senior management team and the board of directors. They are responsible for overseeing the development, implementation, and management of our compliance program, with the goal of ensuring that we maintain an environment of integrity throughout our organization.

To support the implementation of our compliance program, we provide ongoing training to all employees on topics such as anti-bribery and corruption, conflicts of interest, data privacy, and other key compliance areas. We also have established policies and procedures that are communicated to our employees regularly.

As part of our commitment to transparency, we have established systems to ensure that employees and other stakeholders feel comfortable raising concerns or reporting potential violations of our policies or the law. All reports are treated as confidential and are investigated in a timely and appropriate manner.

Our commitment to compliance is central to our business and its success. We believe that by operating our business ethically and with integrity, we can contribute to a better world for all.

HOYA Code of Conduct and Supplier Code of Conduct

HOYA’s Code of Conduct is a guiding document that outlines the values, principles, and standards of behavior expected of all employees, customers, suppliers, and stakeholders of the company. The Code is meant to create an environment of trust, transparency, and integrity. The Code covers various aspects such as the company’s commitment to ethical practices, fair treatment of employees, respect for human rights, environmental sustainability, and legal compliance.

HOYA’s Code of Conduct also sets expectations for the social responsibility of the company by reducing pollution and waste, meeting ambitious sustainable goals, and promoting ethical sourcing and supply chain management practices. Additionally, it outlines all business practices, including how conflicts of interest should be managed, reporting procedures, and accountability mechanisms to ensure adherence to the company’s standards.

The Code outlines the consequences of violating the standards outlined in the document, which can include disciplinary action, termination of employment, fines, or legal action. The values and principles outlined in the code of conduct reflect the company’s mission and culture, and it is essential that all employees, business partners, and stakeholders adhere to it to maintain the company’s reputation and integrity.

COMPLIANCE TRAINING

HOYA has established a robust compliance training program to ensure that all its employees and business partners understand and adhere to all legal and ethical requirements. HOYA’s compliance training program is developed to provide ongoing compliance training to employees, managers, and business partners.

The compliance training program covers a range of topics, including anti-bribery laws and regulations, data privacy, and intellectual property rights. The program provides in-depth knowledge on the risks of non-compliance and the consequences of violating relevant regulations or codes of conduct. The training is delivered through a variety of methods, including classroom sessions, online modules, and webinars.

HOYA offers role-based training to ensure that employees receive the necessary training specific to their job functions. The training program is regularly updated to ensure the training material aligns with HOYA’s evolving policies and regulations.

HOYA’s compliance training program is designed to complement other compliance measures and internal controls, reinforcing the importance of compliance at every level of the organization. The program also offers a feedback mechanism for employees to express their concerns or raise questions to their managers or compliance officers directly.

HOYA’s compliance training program is a key component of the company’s business ethics and regulatory compliance framework. Through its compliance training program, HOYA is committed to maintaining the highest standards of business integrity and compliance.

HOYA Helpline

HOYA Helpline is an integral part of the company’s corporate compliance program, designed to provide an effective channel for employees, vendors, customers, or other stakeholders to report concerns or potential compliance violations anonymously and confidentially. The Helpline is a system that is available 24 hours a day, 7 days a week, and can be accessed through a variety of means, including online reporting and telephone reporting in certain countries.

The purpose of HOYA Helpline is to provide a confidential means of reporting potential compliance violations such as fraud, harassment, discrimination, or other unethical or illegal practices. Individuals who have concerns or suspicions about any violation of the company’s code of conduct, policies, or applicable laws or regulations can use the helpline to report their concerns.

Reports made to the Helpline are handled by independent third-party providers or internal compliance officers trained to handle reports professionally. The anonymity and confidentiality of the individual(s) who report concerns are strictly maintained, and retaliation or discrimination against any employees who report their concerns is prohibited.

Reports made through the Helpline are investigated thoroughly by HOYA compliance officers to ensure that the company’s policies and laws are followed. If the concerns are substantiated, appropriate actions are taken, which may include disciplinary action or other corrective measures.

HOYA Helpline is an important resource for all employees and stakeholders in maintaining a culture of ethics and accountability. Availability of the Helpline makes HOYA a responsible and transparent organization dedicated to promoting compliance and ethical behavior in all its activities.

HOYA Anti-Bribery and Anti-Corruption Policy

Based on the HOYA Code of Conduct, the HOYA Group has established this Global Policy to strengthen its anti-bribery and anti-corruption initiatives. The policy outlines specific measures, including rules, management systems and education, to prevent bribery and corruption, and we believe that acting in accordance with this policy will further enhance the trust of our stakeholders. We will continue to make group-wide efforts.

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