CODE OF
CONDUCT
Chapter 5 :
To Be a Business Person of Good Sense
Mantovani Navigation expects executives and employees to always consider the Group's reputation and prestige, and to appropriately manage and protect all of the Group's tangible and intangible assets.
| 1 | Dedication to work |
• We will distinguish between work and our personal lives and be dedicated to work while we are on duty.
| 2 | Prohibition of conflicts of interest |
• (1) We will strive to act and exercise our judgment so as to benefit the Mantovani Navigation.
• (2) We will not act toward competing companies or third parties against the interests of the Group, or in such a way as could be construed as acting against the interests of the Group.
| 3 | Prohibition of insider trading |
• We will not trade stocks or other securities based on material non-public information. In addition, we will not disclose any material non-public information to our families,acquaintances, etc.
| 4 | Prohibition against receiving personal profit |
• We will not receive any personal profit or benefit from our customers, clients or suppliers by taking advantage of our position.
| 5 | Confidential Information |
• (1) We will strictly manage Mantovani’ confidential information and we will not disclose such information without following procedures specified in internal company regulations, even after retiring from or otherwise leaving the Mantovani Navigation.
• (2) We will not unjustly or improperly use Mantovani’ confidential information at any time, even after retiring or otherwise leaving the Group.
| 6 | Accurate operational records/reports and appropriate account management |
• (1) We will record and report information concerning the Mantovani Navigation’s financial affairs and any business activities accurately, thoroughly, and appropriately. We will not record or report false information, nor alter or falsify information.
• (2) We will carry out account management that is based on generally-accepted accounting principles and standards and comply with applicable laws and internal company regulations.
| 7 | Appropriate management of intellectual property |
• (1) We will maintain and protect the patents, utility models, design patents, trademarks, copyrights, mask work rights, trade secrets and any other intellectual property rights held by the Mantovani Navigation and will follow the procedures specified in internal company regulations when granting rights under or transferring these rights to others.
• (2) We will appropriately manage and use the trademarked logo of the Mantovani Navigation (Mantovani Logo) in accordance with internal company regulations.
| 8 | Appropriate use of Mantovani Navigation assets |
• We will not use or divert Mantovani Navigation assets such as facilities, materials, equipment, cash, and information for private purposes or any purpose other than those related to Mantovani’ business. We will appropriately manage the Group’s assets to prevent incidents such as loss, robbery, leakage, and unlawful use.
| 9 | Appropriate use of information-related systems |
• (1) We will appropriately use and manage information systems and computer networks (“Information-related Systems”) in compliance with applicable laws and internal company regulations. We will not use Information-related Systems for unjust or inappropriate purposes or access them through unjust or inappropriate means.
• (2) We will use Information-related Systems for work purposes, and we will not use such Systems for private or personal purposes.
• (3) We will implement the necessary security measures in order to protect Information-related Systems from computer viruses, as well as information leakage and information system failure caused by unauthorized access, etc.