We prepared the Guidelines for Compliance Actions in January 2007 for the purpose of securing management conforming to laws and regulations and enhancing transparency through the implementation of compliance and then distributed the Guidelines to all employees. We established the Compliance Committee, and the steering office (General Affairs Section, Business Administration Division) implements education programs once or more per year. The company and all of the employees will observe the action guidelines and take action, thereby fulfilling our social responsibility.

1. Guidelines for Compliance Actions

Under the concept that the foundation of business activities lies in societal reliance, we will take action by observing laws and regulations and social ethics, as well, in all of our business activities. We will contribute to the realization of a rich and comfortable society by continually providing new materials to the world through the development of advanced technologies.

2. Compliance Promotion System

Compliance Committee Chairman: President
  Vice Chairman: Vice President
  Committee Members: Persons appointed by managers and the chairman
  Steering Office: General Affairs Section, Business Administration Division

3. Compliance Inquiry Desk

Lion Idemitsu Compliance Inquiry Desk; Steering Office of Compliance Committee

[Items for Compliance]

(1) Relationship with Society

  a. Observation of related laws and regulations;
  b. Protection of personal information;
  c. Environmental conservation;
  d. Security / disaster prevention;
  e. Breaking off of relations with antisocial forces;
  f. Proper account processing and tax payment; and
  g. Contributions in overseas businesses.

(2) Relationship with Customers, Business Partners and Other Companies in the Same Trade

  a. Safety of products;
  b. Observation of the Antimonopoly Law and related laws and regulations;
  c. Respect of inTEL lectual property rights;
  d. Observation of regulations on insider trading; and
  e. Proper disclosure of information.

(3) Relationship with Employees

  a. Preservation of the dignity of individuals;
  b. Observation of laws and regulations related to labor;
  c. Establishment of rewarding workshops; and
  d. Occupational safety and health.

(4) Relationship with Company and Company’s Properties

  a. Proper management of the company’s assets (including inTEL lectual property rights);
  b. Drawing a line between public and private affairs, prohibition of conflict of interest;
  c. Management of confidential information;
  d. Proper use of the information system; and
  e. Prohibition of political activities, religious activities and other soliciting activities.

November 1, 2010 
LION IDEMITSU COMPOSITES CO.,LTD.