Code of Business Conduct

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1 FANUC AMERICA CORPORATION Code of Business Conduct A Message from the President & CEO: Responsibility, trust, respect, and integrity these values represent the history and foundation of FANUC America Corporation. As employees and representatives of this great company, we must demonstrate these values at all times. This Code of Business Conduct sets expectations, helps to guide us, and clearly and openly reinforces these values. I am writing this message to ask that you become familiar with this Code of Business Conduct and what it means. All FANUC America Corporation employees and other representatives are required to read, understand and abide by this document. But for it to really work, this Code must be more than just words on paper. We must confidently act like we share and believe in these values. I also want to reiterate a critical aspect of this process please communicate. Please question, raise concerns, share positive experiences, and always foster transparency. We try to offer every possible means for you to start these conversations: Your supervisor or manager should always be available for you Our HR group specializes in employee communications Our Legal department can be a valuable resource We created the Compliance Committee described at the end of this Code specifically for these types of discussions In case you would feel more comfortable with anonymity, we also offer: o An Employee Reportline ( this system allows you to report a compliance concern or question and is managed by a third party to ensure protection of your identity o Ask the President ( this system generates a nameless directly to me o Ask HR ( this system generates a nameless directly to HR At the same time that you are reviewing this Code, please also consult the message of preciseness and transparency from our parent company and shareholder, FANUC CORPORATION, at This guidance applies to all FANUC employees and provides further backing and enforcement for our ethics program. We all need to uphold FAC s ethical standards to ensure our company is worthy of trust and the best company that we can be. I thank you for your sincere support. Mike Cicco August,

2 Table of Contents 1) Decision Making and Ethical Standards a) A Practical Guide b) Compliance with the Code 2) Honest and Ethical Conduct a) Avoiding Conflicts of Interest b) Gifts, Meals and Entertainment c) Accuracy of Books and Records 3) Compliance With Laws a) Antitrust and Competition Laws b) Political Parties and Government Officials c) Trade Control Laws 4) Protection of Employees and Resources a) Confidential Information b) Employee Health, Safety and Security c) Electronic Media Usage d) Company Resources and Intellectual Property 5) Accountability a) Our Ethics Program b) Report line entries c) Internal Investigations d) Prohibition against Retaliation e) Disciplinary Action d) Equal Employment Opportunity and Workplace Harassment e) Data Privacy Laws f) Inside Information and Securities Trading August,

3 Decision Making and our Ethical Standards At FANUC America Corporation ( FAC ), our long-term success and sustainability depends on choices we make every day, and meeting the expectations of how to behave in business at all times. Decisions will be based on our principles and values, and on our dedication to professional business conduct. FAC will not tolerate dishonesty, fraud, or deceit in any way. Decisions will be based on fact and fairness, not bias or prejudice. A Practical Guide Each day you will make decisions that are critical to our success. This Code is a practical guide that you can use to get the information you need to make good decisions. You will learn when to report issues and contact management. Our Code contains brief summaries of certain FAC policies. All FAC employees are expected to comply with all applicable corporate policies, standards, and procedures issued by all departments and divisions of FAC. FAC s Code of Business Conduct is not an employment agreement. Compliance with the Code This Code applies to all officers, employees, and contract workers of FANUC America Corporation, and its subsidiaries, whether operating inside or outside of the United States. We expect our suppliers, vendors, contractors, and other partners to develop ethics and compliance programs that are consistent with our values in all material respects. Everyone at FAC will: Understand how this Code applies to their work, business decisions and actions. Demonstrate integrity and leadership by complying with the Code and promoting compliance by others. Know that adherence to this Code is an element in evaluating the performance of everyone at FAC. August,

4 FAC conducts business in countries around the globe and is subject to the laws and regulations of each of these countries. We recognize the global reality of our work. In some cases, there may be a real or apparent conflict between the laws of two or more countries. In that event, FAC will obtain legal advice immediately to understand how to resolve the conflict. Honest and Ethical Conduct FANUC America Corporation will deal honestly and ethically with our employees, customers, suppliers, competitors, and other stakeholders. Avoiding Conflicts of Interest A conflict of interest occurs when your private interests interfere, or appear to interfere, with the interests of the company. When dealing with customers, suppliers, distributors, contractors, competitors or any other person doing business with FAC, employees are to act in the best interest of the company. Employees are to disclose any potential situation involving an actual or potential conflict of interest. Personal business relationships or organizational relationships with vendors or competitors are examples of possible conflicts of interest. Gifts, Meals and Entertainment FAC competes solely on the merits of our products and services. Our organization will not seek, accept, offer, promise directly or indirectly, provide items of value including payments, fees, loans, services, entertainment, favors or gifts as a condition or as a result of doing business with FAC. Accuracy of Books and Records All FAC books, records and accounts must accurately reflect the nature of the transactions recorded. It is your responsibility to record all costs accurately and to follow all accounting procedures. No false or misleading entries should be made in our books and records. You must carefully follow FAC policies on document retention, including electronic documents and s. Never destroy any documents that you believe might be relevant as evidence in any regulatory proceedings or court actions. August,

5 Compliance with Laws FANUC America Corporation employees are required to be familiar with the laws, rules and regulations that apply in the areas and within the scope of their work responsibilities. Antitrust and Competition Laws Antitrust and competition laws prohibit agreements that eliminate or discourage competition. Violations of these laws carry stiff monetary fines and jail terms. FAC complies fully with the antitrust and competition laws of every jurisdiction where we do business and is committed to fair and competitive sales practices. We will not communicate either formally or informally with competitors to fix or control prices, allocate markets, boycott customers or suppliers, or limit the sale of products. In this regard, we have the following responsibilities: 1) Avoid even informal or casual conversations with employees of our competitors regarding prices, products, or customers 2) Never make inaccurate or malicious statements about our competitors Be mindful that the antitrust and competition laws are not limited to activities within the U.S. These laws apply horizontally to competitors and vertically to resellers and customers. August,

6 Political Parties and Government Officials FAC does not contribute directly or indirectly any form of corporate asset or funds to any political party or campaign. We encourage employees to participate individually in political affairs on their own time and resources. FAC may not directly or indirectly pay, give, offer, or promise money or anything of value to any officer, employee or representative of a government or of a public international organization in order to: (1) Secure an improper advantage in obtaining, retaining, or directing business, (2) Influence any act or decision of the recipient in an official capacity, or (3) Induce the recipient to do or omit to do an act in violation of such person s lawful duty. You must never offer, give, ask for, or receive any form of bribe or kickback. Favorable treatment may often appear innocent; however it is illegal when offered in exchange for another gift, including business considerations. Trade Control Laws While importing or exporting products, services, information or technology, FAC complies with all applicable customs, anti-boycott, embargo, trade control laws, rules and regulations. The United States embargo and trade control laws prohibit, restrict, or regulate transactions in goods, funds, services, or technology with certain persons, companies, and countries based on national security and policy interests. Employees who have responsibility for the importation or exportation of products, services, or funds or the transfer or disclosure of technology must be familiar with and comply with these laws, rules and regulations. Equal Employment Opportunity and Workplace Harassment Our success depends in great part on our work environment. FAC provides employment opportunities without regard to race, religion, color, national origin, sex, age, veteran status, marital status, pregnancy, disability or any other protected status. Decisions as to hiring, promotion and other aspects of the employment relationship are based solely upon job-related qualifications. August,

7 FAC prohibits sexual harassment, as well as harassment based on any of the other characteristics described above, and will take appropriate action to eliminate harassment and remedy the effects of such actions. Understand and abide by all corporate policies, procedures, and work rules relating to employment and workplace fairness. It s our responsibility to treat fellow employees fairly. Data Privacy Laws FAC is committed to the protection of individuals privacy and the privacy of our customers and others with whom we do business. Privacy laws and regulations are complex and differ from country to country. FAC complies with applicable privacy laws, rules and regulations wherever we do business, and in all aspects of its business. We earn the trust of our customers and employees by protecting the privacy of their information. Inside Information and Securities Trading We must remember that FAC s parent company and shareholder, FANUC CORPORATION, and many of our customers and suppliers are public corporations. To that end, FAC employees may be exposed to information about these companies that is not public and material to the performance and the stock price of that company. FAC employees must respect and comply with securities laws that govern the handling of this information and the trading of securities while in possession of this information. August,

8 Protection of Employees and Resources FANUC America Corporation s assets, such as intellectual property, electronic media, working time, equipment, funds, products and services, are intended for legitimate business use only. Confidential Information The disclosure of company-confidential information regarding FAC s business, financial, legal, regulatory or engineering operations, whether intentional or accidental, can adversely affect the stability and competitive position of FAC, including the job security of its employees. Because of this risk of harm to FAC and its employees, do not, during the term of employment or after, release to third parties any companyconfidential information except pursuant to a confidential disclosure agreement, or legal mandated. Company-Confidential Information means all non-public information in FAC s possession, whether through internal or external development or other sources, that might be of use to competitors, or harmful to the financial or competitive position of FAC if disclosed. Do not accept non-public information provided by a customer, supplier or other party with the condition or understanding that it is kept confidential unless such information is subject to a written confidential disclosure agreement. When disclosure is legally mandated, FAC will maintain the confidentiality of information entrusted to FAC by a customer or other third party only to the extent permitted by applicable law. Employee Health, Safety and Security FAC is committed to protecting the health and safety of its employees and will act promptly to address any unhealthy or unsafe condition. We do not tolerate any unsafe behavior committed by or against our employees. Each employee has the responsibility to follow health and safety requirements and observe established safe work practices to ensure their own safety and that of co-workers. This includes reporting to work free from the influence of drugs or alcohol that could impair one s ability to work in a safe and conscientious manner. August,

9 If you are involved in, or know of, an accident or dangerous situation, it is your duty to report it to management promptly and, when appropriate, take corrective action. Electronic Media Usage Similar to other corporate assets, our information technology is a company resource that must be used only to further our company s business. FAC provides access to and use of electronic mail, voic , the Internet, and other electronic media for business purposes. Do not use FAC electronic media for any purposes that violate applicable laws, rules and regulations or FAC standards, policies or procedures. This includes transmission of threatening, obscene or harassing materials. Where permitted by local laws and regulations, the company may exercise its rights to inspect its property, electronic communications, and all other resources and assets. Incidental personal use of electronic media that does not interfere with FAC s business or an employee s performance of their job responsibilities is acceptable, as long as such use does not include illegal, unethical or otherwise offensive subject matter. Company Resources and Intellectual Property The assets, property, and resources of FAC should be used primarily for business purposes. Company resources include but are not limited to: computers, telephones, electronic mail, Internet access, voice mail, equipment, tools, and vehicles. Our intellectual property is also a valuable asset. This includes copyrights, patents, trade secrets, trademarks, ideas, inventions, and processes. We respect and protect company resources and intellectual property, whether it belongs to us, our customers, or to others. August,

10 Accountability We are all responsible for acting ethically. We must accept and fulfill our duties to each other. Our Ethics Program At FANUC America Corporation, we believe that management and employees share accountability for business ethics. The company provides tools and resources to help all of us understand and maintain our standards of ethical business conduct. Each employee has a personal responsibility to observe FAC's Code of Business Conduct with attention to both the detail and the spirit of the statement. Managers at all levels are responsible to take timely action, including remedial action as necessary whenever a suspected violation of this Corporate Code of Conduct occurs. Each manager should seek the counsel and guidance of higher management and/or a member of the FAC s Compliance Committee where required. Any employee who becomes aware of any violation of law or of this Corporate Code of Conduct must promptly report this information to higher management or Human Resources or, if the employee believes it cannot be adequately dealt with otherwise, to a member of FAC s Compliance Committee, and/or FAC s Compliance Manager. The members of FAC's Compliance Committee are: Sue Harmon, Manager Human Resources Mahesh Jadhwani, General Manager CNC Finance Bernard T. Lourim, General Counsel Karen St. Louis, Director - Human Resources Steve Stanko, Senior Vice President and CFO FAC s Compliance Manager is Mike Hartmann It is important that all employees observe FAC's Code of Business Conduct and report suspected instances of any failure to do so. The reputation and future economic viability of FAC may be at stake. August,

11 No single code can cover every situation that may occur. If at any time you are unsure of what is the "right thing" to do, talk it over with your supervisor, the Human Resources Department, the Legal Department or the Compliance Committee. Report line entries Although most questions and concerns can be resolved by discussing them with your manager, the Ethics Report line provides an additional way to get help, should you feel uncomfortable talking to management about an issue. The Report line is not intended to replace conversations between employees and managers, but rather to provide an additional resource to employees. You can contact our Ethics Report line at any time to ask a question, express a concern or report a possible violation of laws, regulations, or policies. When reporting a concern, you may be asked to provide the time, location, names of the people involved, and other details so that we can investigate your concerns. Every entry to the Report line is handled promptly, discreetly, anonymously if you choose to do so, and professionally. You may access the Report line at Or toll-free at the following telephone numbers: Argentina Brazil Canada (English) (French) Mexico USA All questions and reports received via the Ethics Report line are reviewed promptly. Matters are forwarded to the most suitable functional area within FAC for investigation and resolution. Appropriate action will be taken to resolve each reported matter. Internal Investigations FAC will promptly investigate all alleged and potential violations of this Code, or of any related FAC standard or policy. Investigative actions will be conducted only by formally assigned staff. Upon resolution of an investigation, FAC will take appropriate remedial actions. August,

12 No person other than those assigned as set forth above may conduct his or her own investigation. Employees have the right to report any concerns or suspected violations of the Code to the appropriate Supervisor, Manager, or through the Report line. Prohibition against Retaliation FAC will not retaliate against any person who brings an ethics or compliance issue to our attention. Individuals who raise concerns or help resolve reported matters are protected against retaliation. Anyone who uses the ethics and compliance program to spread falsehoods or damage another person s reputation will be subject to disciplinary action. Discouraging other employees from making a report or getting the help they need is prohibited, and could result in disciplinary action. Disciplinary Actions Violations can jeopardize our relationships with customers and suppliers, and could even result in losing the privilege to do business in the countries where we operate. Employees who violate the laws, regulations, or our policies are subject to disciplinary action in accordance with applicable laws, which may involve any of a variety of measures as appropriate, up to and including dismissal. All disciplinary action is decided on a case by case basis. If FAC determines that corrective action is necessary to fix a problem and avoid the likelihood of its recurrence, FAC will promptly decide what steps to take, including legal proceedings when appropriate. August,

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