PROCUREMENT POLICY




1.    Compliance with laws

a.

The ULVAC Group will conduct corporate activities based on laws, regulations, social standards and common sense.

b.

The ULVAC Group will fully comply with related laws and regulations. (Local laws and regulations: Anti-Monopoly Law, Commercial Code, Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors, Stamp Tax Law, Foreign Exchange Law, Copyright Law, Act on Protection of Personal Information, etc.)



2.    Maintenance and promotion of fair and free competition

a.

The ULVAC Group will maintain and promote fair, impartial and free competitions to our suppliers throughout the world.

b.

The ULVAC Group will prohibit all employees from requesting unfair business transactions to our suppliers by abusing our advantageous positions especially as a customer.



3.    Sound and mutually prosperous relationships with suppliers and related parties

a.

The ULVAC Group will prohibit all employees from offering and receiving unfair gain in commercial transactions both within the Group and with third parties. Directors and employees will make sound judgments and moderately conduct to prevent misunderstanding or negative appraisals by society.

b.

The ULVAC Group will prohibit all employees from forming personal relationships with suppliers. The followings are non-exhaustive list of examples of prohibited behavior for all employees:

Accepting any money, gift certificate or gifts from a supplier.

Acquiring stocks in a supplier prior to an IPO based on unlisted information.

Accepting meals, golf and other forms of entertainment provided by a supplier.

Having dinner with a supplier beyond the bounds of reasonable social standards.
Dinner within the bounds of reasonable standards shall be shared equally with permission of the related division of the company.

Disclosing unlisted information about its company related to insider trading to a supplier.



4.    Promotion of global procurement

a.

The ULVAC Group will expand its activities globally to acquire the best-quality parts and materials in line with its corporate activities.

b.

The ULVAC Group will cooperate with global suppliers and procure excellent parts, materials, technologies and services with international outlook.



5.    Promotion of green procurement

a.

Recognizing that environmental conservation is one of the highest-priority challenges for humanity, the ULVAC Group has committed itself to the conservation of the Earth's natural environment and is making contributions toward society's environmentally sustainable growth and development.

b.

The ULVAC Group has established the Green Procurement Standards and will promote procurement activities with consideration of environment.