CODE OF
CONDUCT
Chapter 3 :
For Sincere and Fair Operational Activities
Mantovani Navigation will seek to attain higher quality of all our group's products and services to ensure the constant satisfaction of and reliability for our customers. We will also pursue higher levels of safety in order to comply with all applicable laws and safety standards.
Mantovani Navigation will also carry out all corporate activities fairly and reasonably, complying with anti-monopoly Law and all applicable laws related to our operational activities.
| 1 | Providing safety, trusty, and high quality products and service |
• (1) We will provide products and services with full consideration for their safety, reliability, and quality. Products and services supplied to customers must meet all legally mandated product safety and quality standards and internal company regulations.
• (2) We will strive to provide customers with all relevant information needed in order to safely and confidently use and handle our products and services (e.g. product specifications, usage conditions, and correct usage environment etc.)
• (3) If a safety or quality problem should occur with a Mantovani product or service, we will quickly identify the root cause, implement corrective measures, and take action to prevent a recurrence.
• (2) We will strive to provide customers with all relevant information needed in order to safely and confidently use and handle our products and services (e.g. product specifications, usage conditions, and correct usage environment etc.)
• (3) If a safety or quality problem should occur with a Mantovani product or service, we will quickly identify the root cause, implement corrective measures, and take action to prevent a recurrence.
| 2 | Ensuring to execute contracts |
• (1) When starting business dealings, we will carefully consider the contract contents and conclude lawful and fair contract. Then we will sincerely execute the signed contracts.
• (2) When we conclude contract, we will follow a procedure set forth in internal company regulation.
• (2) When we conclude contract, we will follow a procedure set forth in internal company regulation.
| 3 | Fair Competition |
• (1) We will take no action such as making contracts, agreements, or otherwise that restricts prices, sales, quantities, technologies, products, equipment, clients, etc. We will not act in any way that could be interpreted as forming or participating in a cartel.
• (2) We will not participate in any gathering or conversation (including golfing or social events), official or unofficial, with competitors that may be construed as an attempt to restrict competition unless there is a lawful reason. We will not exchange or receive prohibited competitive information by means of social conversations, phone calls, or e-mails, especially in regard to the matters referenced in 3(1) above.
• (3) We will not act in any way that could be interpreted as restricting free and fair competition such as excluding or controlling the business activities of other companies, or preventing new entrants to the business areas in which we operate.
• (2) We will not participate in any gathering or conversation (including golfing or social events), official or unofficial, with competitors that may be construed as an attempt to restrict competition unless there is a lawful reason. We will not exchange or receive prohibited competitive information by means of social conversations, phone calls, or e-mails, especially in regard to the matters referenced in 3(1) above.
• (3) We will not act in any way that could be interpreted as restricting free and fair competition such as excluding or controlling the business activities of other companies, or preventing new entrants to the business areas in which we operate.
| 4 | Appropriate relationships and fair dealing with sales partners |
• (1) We will strive to create equitable and fair relationships with sales partners.
• (2) We will not engage in unfair or unjust dealings with sales partners so as to unjustly restrain their business (e.g. restrictions on resale prices, customers, marketing methods, etc.), exclude their business activities, and unfair discrimination, high pressure sale, resale price maintenance etc.
• (2) We will not engage in unfair or unjust dealings with sales partners so as to unjustly restrain their business (e.g. restrictions on resale prices, customers, marketing methods, etc.), exclude their business activities, and unfair discrimination, high pressure sale, resale price maintenance etc.
| 5 | Fair procurement from suppliers |
• (1) We will treat all suppliers equally and choose them for business dealings based on reasonable comparison and evaluation.
• (2) When we deal with suppliers, we will not engage in unfair or unjust activities such as excluding their business activities or abusing a dominant position (e.g. unjust restraints on business activities, forcing mutual dealings, delaying subcontract payments, unreasonably returning goods, demanding unjust price reductions, etc.).
• (2) When we deal with suppliers, we will not engage in unfair or unjust activities such as excluding their business activities or abusing a dominant position (e.g. unjust restraints on business activities, forcing mutual dealings, delaying subcontract payments, unreasonably returning goods, demanding unjust price reductions, etc.).
| 6 | Compliance with import and export laws |
• As a member of the global society, when we import or export products, technology, services, etc., we will strive to maintain international peace and security, and will comply with all relevant domestic and international laws and internal company regulations relating to import and export activities.
| 7 | Advertising and public relations |
• (1) will not make false representations or indications concerning the quality, performance, specifications, place of manufacture, or manufacturing methods of our products and services, or condition to transaction in our sales activities such as advertising and public relations, nor will we make representations or indications that may mislead customers.
• (2) We will not make representations or indications that defame third parties.
• (2) We will not make representations or indications that defame third parties.
| 8 | Respect of intellectual property rights and confidentiality of third parties |
• (1) We will respect patents, utility model rights, design patent rights, trademarks, copyrights, mask work rights, trade secrets, and any other intellectual property rights held by third parties. We will not intentionally infringe or unlawfully use the intellectual property of third parties.
• (2) We will strive to manage Internet and software usage to prevent the finfringement of third parties’ copyrights and the copying, installing and use of software in violation of the applicable licensing terms
• (3) We will not access or obtain confidential information owned by a third party through unlawful means. We will strictly manage the confidential information of third party in accordance with nondisclosure agreements and other such contracts, and will not improperly use the confidential information of third parties.
• (4) We will collect, use, and manage personal information appropriately and in accordance with applicable laws and internal company regulations.
• (5) We will collect, use, and manage personal information appropriately and in accordance with applicable laws and internal company regulations.
• (2) We will strive to manage Internet and software usage to prevent the finfringement of third parties’ copyrights and the copying, installing and use of software in violation of the applicable licensing terms
• (3) We will not access or obtain confidential information owned by a third party through unlawful means. We will strictly manage the confidential information of third party in accordance with nondisclosure agreements and other such contracts, and will not improperly use the confidential information of third parties.
• (4) We will collect, use, and manage personal information appropriately and in accordance with applicable laws and internal company regulations.
• (5) We will collect, use, and manage personal information appropriately and in accordance with applicable laws and internal company regulations.
| 9 | Prohibition of illegal entertaining and gift exchanging |
• (1) We will carry out entertaining and gift exchanges between the Mantovani Navigation and trading partners, etc. in compliance with applicable laws and internal company regulations. We will not act in any way that deviates from sound business practices or that transgresses social norms.
• (2) We will not act in any way that could be interpreted as offering money or any other kind of benefit to public officials or other such persons with the aim of gaining an unfair or illegal business advantage.
• (3) We will not act any way that could be interpreted as bribing or offering / promising / providing profits and / or benefits to foreign public officials such as officials of foreign governments, regional public organizations, or international organizations with the aim of gaining an unfair or illegal business advantage.
• (2) We will not act in any way that could be interpreted as offering money or any other kind of benefit to public officials or other such persons with the aim of gaining an unfair or illegal business advantage.
• (3) We will not act any way that could be interpreted as bribing or offering / promising / providing profits and / or benefits to foreign public officials such as officials of foreign governments, regional public organizations, or international organizations with the aim of gaining an unfair or illegal business advantage.