SANKO: Code of Ethics Manual & Code of Conduct

CODE OF ETHICS

Sanko Diecasting (Thailand) Plc.

INDEX Page Message from the Chairman VISION MISSION & OUR CORE VALUE Code of Ethics Code of Conduct

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1. Conflict of Interest Policy 2. Corporate Assets Policy 3. Gifts and Entertainment Policy 4. Securities tradingg and Inside Information Policy 5. Internal Controls and Audits Financial Reporting 6. Shareholders Policy 7. Customer Relations ions and Product Quality Policy 8. Suppliers /Creditors Policy 9. Rivals Policy 10. Employees Policy 11. Employee Practice Policy 12. Environment and Community Policy 13. Corruption Policy Implementationn and Enforcement and Mechanism 1. Set out the responsibility for the Directors, Managers and all members of staff to acknowledge and follow strictly.

2. Penalty Guidelines 3. The inquiry techniques and the report, in the case of the Company’s ethics www.sankothai.net

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violation by providing multiple channels for complaints.

4. Follow up procedures 5. Amendments and Cancellations 6. Review 7. Effective Date Agreement of Understanding“Code of Ethics�

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CODE OF ETHICS

Sanko Diecasting (Thailand) Plc.

Message from the Chairman

For all these times that the Company has operated under the principle of good corporate governance, with the emphasis on fair operating practices in order to create business growth and the value added for the Organization and for all stakeholders, the Company is fully aware that the honest and ethical cooperation of the Directors, Managers and all staff members is the key factor for leading the Company on the road r to success. Therefore, the Company has provided the ‘Code ‘ of Ethics’ which demonstrates the desired behaviors at work, so that all members may use it as work guidelines and understand the good practice which belong to the same standard.

The Company pany hopes that the Directors, Managers and all members of staff will acknowledge and uphold this code of ethics as a guideline when working, so that we may further improve our Organization to sustainable future together.

Mr. Masami Katsumoto Chairman of the Board of Director and Chief Executive Officer Sanko Diecasting (Thailand) Public Company Limited.

August 2015

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VISION MISSION & OUR CORE VALUE VISION : Sanko has a commitment to be proficient, to lead in the Die Casting Industry and to be recognized internationally; Continuing to acquire innovations in all its operations and create new products obtaining its own trademark; Producing quality products and services for customer satisfaction and business sustainability.

MISSION : 1. Perform with excellence in all its operations.

2. Create innovations ns and use modern technologies in designing and production development.

3. Mobilize employees’ potentials in creating its company’s very own brand within the year 2019 as a common goal.

OUR CORE VALUE : • Innovation • Proactive Working • Achievement Orientation • Sense of Belonging

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Code of Ethics The Company’s regulation on the Code of Ethics for the Board of Directors and the members of staff to strictly follow are as follows; 1. Conduct the business with the partners and competitors on the basis of honesty and the principle of fair practice.

2. Enhanced the strength of the business by focusing on becoming the long term business owner and avoid any actions which may compromise that principle.

3. Strictly uphold the laws by avoiding any legal action that does not fo follow llow with the Company’s Code of Ethics just for the purpose of achieving the business’ goals.

4. In order to maintain the reputation of the Company and the business, avoid disclosing the internal information both direct and indirectly to third parties espe especially cially information which has not been certified by the Company or relating parties.

5. In the case of the conflicts of interest, solve the problem through means of negotiation and together with the Company’s regulation for each specific case.

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Code of Conduct 1. Conflict of Interest Policy 1. Directors and staffs must avoid any actions which may cause a conflict of interest with the Company, be it from the communication with the Company’s trade partners such as business partners, customers, competitors or from utilizing the Company’s information derived from the Directors or the staffs for personal gains and also conducting businesses which competes with the Company or being employed in any other jobs that directly affects the work at the Company. pany.

2. Directors and staffs must avoid holing the shares of the competing companies if it results in the misconduct or affects the work and duties at the Company. In the case that the Directors or the staffs have owned the shares prior to becoming the Directors Directors or the staffs of the Company, before the Company moves into the specific business or through inheritance, the Directors of the staffs must notify their superiors accordingly.

3. Any actions or decisions made by the Managers or the members of staff of the Company must consider the benefits of other stakeholders.

2. Corporate Assets Policy 1. Directors and staffs have the responsibility to look after the Company’s assets so that they are not lost or damaged, and use the assets efficiently to benefit the Company the most and not for personal or other’s benefits.

2. The assets mean both tangible and intangible assets for example, movable properties, immovable properties, technology, academic knowledge, certificate of ownership, patent, copyright including confidential confidential information which is not disclosed to the public, for example, business plan, financial or human resource information.

3. Directors and all members of staff must avoid disclosing or utilizing the Company’s confidential information at all costs.

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3. Gifts and nd Entertainment Policy 1. Directors and staffs must not request, accept or allowed to receive money, gifts or any benefits from those related to the Company’s business.

2. Directors and staffs may accept or give presents conventionally whereas the present must not affect the decision of the business in anyway.

3. The gifts should be something of small value and should not be cash, or equivalent to cash.

4. If the Directors or staffs receive gifts conventionally which has unusually high value from those relating to the Company’s business, they should report to their superior.

5. The giving or receiving of gifts can be done as long as it is done transparently or in the public place or can be displayed.

4. Securities Trading and Inside Information Policy Stock Holding 1. Inform the Directors and the Managers that they have the responsibility to report their own stock holding, spouse and minor child in accordance with the sector 59, including the penalty by sector 275 of the Securities and Exchange Act B.E 2535 and accordin according to the regulation of the Stock Exchange of Thailand (SET).

2. Directors and Managers must notify the trading of the Company’s assets at least 1 day before trading the stocks. This is done by notifying the Company’s secretary and the secretary further informs the Board of the Directors. Once the trading is complete, the (meeting?) is arranged in order to report the stock holding and presents it to the Securities and Exchange Commission and the Stock Exchange of Thailand, and then have the Directors and the Managers report the change in the stock holding to the Board of Directors. This is to prevent the selling or buying of stocks by using inside information and to avoid criticism regarding the appropriateness for the trading of stocks of inside individua individuals.

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Inside Information Policy 1. Directors, Managers and staffs must avoid utilizing inside information for personal gains in buying or selling the Company’s stock, or giving inside information to third parties for the purpose of buying or selling the Company’s Compa stock.

2. Directors, Managers and staffs must not buy or sell the Company’s stock 1 month prior to the release of the financial statement or the release of the Company’s status, including other sensitive information and should wait for at least 24 hours after the information is reveled to the public before buying or selling the Company’s stocks.

3. In the case of a violation and the inside information of the Company has been used for personal gains, the penalties vary from verbal discipline to expulsion from work.

5. Internal Controls and Audits Financial Reporting 1. The Management of the Company is responsible for delivering on time the up-to-date up and accurate financial report both annually and quarterly which is done according to the standard of the accounting practice.

2. Ensure the efficient internal control system so so that the Company follows all the related laws and regulations under the internal auditor and the inspection of the audit committee.

6. Shareholders Policy 1. Any decisions made by the Board of Directors must be done with the benefits of the shareholders ers at its core.

2. Perform the duties to the utmost of the abilities and with honesty. Proceed all actions with fairness to all shareholders.

3. Constantly report the status of the Organization to the shareholders accurately and truthfully.

4. Inform the shareholders of the Organization’s future trends both positive and negative and with enough backing evidence.

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7. Customers Relation and Product Quality Policy Business Partner Selection Policy 1. Do business with partners in automotive, electronics and other related products that possess stability in the endowed field.

2. Business partners that recognize human rights and labor policy. No human rights violations and do not tolerate child labor.

Business Customers and Conduct Policy 1. Display commitment, satisfaction satisfaction and confidence to customers. Ensure in getting better products, services and quality at a reasonable and competitive price by constantly and proficiently maintaining the company’s excellent standard.

2. Commitment to create innovative technology and new management management to make the best profit for customers. Making enthusiastic effort in using resources to the most effective cost and environmentally sustainable.

8. Suppliers / Creditors Policy 1. Treat the customers and the creditor fairly, equally and on the basis of fair returns to both parties.

2. Strictly follow the contract or any terms that were agreed upon. In the case that any of the terms cannot be followed, immediately notify the customers and/or the staffs in advance so that both parties can work out the solution.

3. When negotiating the business, avoid requesting, accepting or hiring any benefit which is dishonest in the business to the customers and/or creditors.

4. If there are any information regarding the dishonest requesting, accepting or hiring any benefits, the individuals must reveal the information to the partners and/or creditors, and work together to solve the problem quickly and fairly.

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5. Constantly inform the creditors about the financial information fully, accurately and on time.

9. Business Competitors & Conduct Policy.

1. Practice to compete in accordance with the law and international standard rules.

2. Keep the connection with the competitors which may be developed as a commercial partner in the future.

10. Employees Policy 1. The Company selectss the staffs and the contractors based on the suitability of the qualification and the performance without any prejudice on gender, religious beliefs, nationality, age, birth place or physical condition.

2. The Company provides sufficient benefits and fair compensations to all members of staff.

3. The Company provides a safe environment at work for the health, assets and the quality of life of the staffs.

4. The promotion, relocation including the rewards and penalty of the staffs are done through honesty and under moral principles. This takes into account the knowledge, abilities and the appropriateness of the staffs as the core.

5. The Company gives oppo opportunities rtunities for staffs to thoroughly and constantly improve their skills, knowledge and the abilities both for the work and for their daily lives and also encourages them to be able to care for themselves when they reach retirement.

6. The Company follows the the laws and regulations concerning the staffs strictly.

11. Employee Practice Policy 1. Self-practice 1. Perform one’s duty with transparency, honesty and determination.

2. Avoid giving gifts to the superiors or receiving gifts from the subordinates.

3. Uphold honesty. Do not engage in any actions that may compromise one’s reputation or the Company’s reputation.

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4. Be responsible to the tasks given, including improving and educating one’s self at all times so that one can work effectively and efficiently. efficient 2. Treating the Customers, Society and Relating Parties 1. The staffs must keep the customers information confidential and not reveal them to others.

2. The staffs must not use the customer’s information for personal gains or for third parties which ch may lead to any actions or decision that may result in a conflict of interest of the Company and the shareholders.

3. The staffs must not use news and inside information or non-public non public information to benefit the trading or personal investment which may cause the loss of benefits to the clients of the Company.

4. The staffs must not use their authorization as the Company’s staffs for undesirable personal gains.

3. Treating Other Staffs 1. Encourage and protect the unity between the staffs. Cooperate and support each other.

2. Treat other staffs kindly and not withholding necessary information for the operation to other staffs and constantly improve yourself in order to work with others.

3. Respect the rights of other staffs in the Organization. Refra Refrain in from criticizing others in the way that it may cause damage and not taking others’ achievements as your own.

4. Attitude towards the Organization 1. Strive to be disciplined and follow the rules, regulations and the culture of the Organization even though they may not be written down.

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2. Create and maintain the aspect of unity and the togetherness of the staffs. Avoid any actions that may affect the reputation or the image of the Company or could cause problems to the Company in the t future.

5. Political Rights 1. The Company encourages the staffs to be good Samaritans and exercise their political rights under the Constitutional Laws and any other related laws.

2. The Company allows freedom of speech and opinion to the staffs concerning conc politics but not in the name of the Company and that it would not in any way affect the reputation of the Company.

3. The Company does not participate in any political events and will not give any opinions that may cause misunderstanding that the Company Company involves with or supports any particular political party or any particular movements which may lead to the disharmony within the Company and in the country.

4. The Company will not use its assets to support any political parties or any movements in exchange xchange for unlawful benefits.

12. Environment and Community Policy Sanko Diecasting (Thailand) Public Company Limited, the automobile parts producing company, is determined to operate with the responsibility to all of the influences caused by the Organization’s activities. The Company operates its business based on transparency, ethical and with respects to human rights and the benefits of the stakeholders.

The Company strives to produce high quality and safe automobile parts for the consumers and nd is also considerate to the society and the environment by complying with the laws and regulations, including the standards practice related. The Company also aims to develop and improve itself in order to establish and sustain a solid foundation of resp responsibility onsibility for the society

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13. Corruption Policy The Directors, Managers and the Company’s staffs all have the responsibility to prevent and oppose the corruption by encouraging the honest conscience under a strong work system with efficient internal control trol system and all together giving importance to and follow the anti-corruption anti policy.

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Implementation and Enforcement and Mechanism 1. Set out the responsibility for the Directors, Managers and all members of staff to acknowledge and follow strictly.

The Board of Directors should be a good representative of the shareholders by considering the sustainable growth of the company, constantly issue the dividends sufficiently, manage the Company to the full potential with honesty, ethical and care, not pursuing any particular political parties, have the freedom of actions and decisions and do not have stakes in any business relating to the Company or competing with the Company. Above all else, strives to prevent and eliminate all forms of corruption.

The Managers and staffs should strive to develop and strengthen the culture of teamwork, satisfying the customers’ needs, be fair and be honest when operating the business. Always be aware and concern about the safety of the society, environment and and the people’s quality of life, including performing the tasks with responsibility, honesty, determination and dedication by prioritizing the benefits of the Company first.

2. Penalty Guidelines Staffs that disobey or do not follow the Code of Ethics will be accountable for the following disciplinary actions; 1. Verbal warning 2. Written warning. The warning letter lasts for 1 year since the date of violation by the staff.

3. Suspension from work wor without pay (No more than 7 days) 4. Expulsion from work with pay.

5. Expulsion from work without pay.

Remarks: The punishment for the offender or those that do not follow the Code of Ethics will be evaluated depending on the cases together with the past behavior and the intention of the www.sankothai.net

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offenders. However, the Company may use one or many of the disciplinary actions at the same time and in any order.

3. The inquiry techniques and the report, in the case of the Company’s ethics violation by providing multiple ple channels for complaints.

The Company is aware and always considers the rights of the stakeholders and will not proceed with any actions that may violate or undermine the rights of the stakeholders who are shareholders, staffs, customers, business partners, partners, competitors and creditors, including the community, society and the environment. The Company allows the stakeholders and those related to the business to have access to multiple channels for suggestions, opinions, complaints or any leads seen in any events or actions which may affect the violation of laws, regulations and/or in conflict with the morals and ethics that could cause the damage to the Company. The Company sets the guidelines to be acknowledged as follows; 1. Stakeholders or witnesses may directly report to the Company at; The Chairman of the Board of the Audit Committee Sanko Diecasting (Thailand) Public Company Limited 3/14 M. 2, T. Nong Bua, A. Ban Kai, Rayong, 21120 Or through the Company’s website: www.sankothai.net The Chairman of the Board or the Audit Committee will receive the information directly by keeping them confidential in order to protect the stakeholders and the witness and will carry on the procedure fairly by referring to the information received and prove it to further handle the situation.

2. When the Company receives a filing complaint, the Company sets the procedures as follows; 1) Gather all the evidence regarding the violation or disobeying of the Code of Ethics. www.sankothai.net

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2) Present the case to the inspector in order to carefully investigate the evidence in detail. When the investigation is over, implement the measures to stop the complaints, notify the witness and also report to the Company.

3) If the appellant ppellant is not satisfied with the steps of procedures to stop the complaints, the appellant can appeal against the procedures, and if the appellant is not satisfied with the result of the appeal’s decision, he/she has the rights to pursue other options according to the laws.

4) The leap time for filing the complaints. The complaint will be sent to the investigator within 7 working days since the day of filing the complaint. If the appellant is not satisfied with the procedures to stop the complaints, he/she he/she may appeal within 7 days since procedures have started.

5) The person receiving the complaints is responsible for notifying the appellant of the result if the appellant reveals his/her identity. In the case of an emergency, report directly to the Chairman Chairman of the Board and/or to the Board of Directors.

However, in order to protect the rights of the appellant and the reporter who acted in good faith, the Company will not reveal the names, address or any information which may lead to the appellant or the reporter and will keep those information confidential by limiting them within the authorized personnel of the investigation that can gain access to this information. To this, the person receiving the complaints have the responsibility to safeguard the comp complaints information and any relating documents confidential and not reveal this information to unrelated third parties unless it is specified by the law.

4. Follow up procedures The Directors, Managers and all members of staff of the Organization have the duty and the responsibility to strictly follow the policies set in the Code of Ethics in order to achieve the business goals based on ethics and morality. For the benefits of the stakeholders, the shareholders, the Company and the society, all levels of tthe he Managers in the Organization must make sure that their www.sankothai.net

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subordinates understand and values the idea of strictly following the Code of Ethics of the Company.

However, it is impossible for the Code of Ethics to cover every single situation. Therefore, the Directors, Managers and staffs must use their own judgment and act correctly according to the situations. If there are any problems or concerns regarding the operation, consult the seniors or any relating departments such as, the Human Resource Department or the Internal Audit Department.

5. Amendments and Cancellations The amendments or the cancellations of the Company’s Code of Ethics must be presented to the Audit Committee and the Board of Directors to evaluate and approve.

6. Review The Board of Directors ctors and the Audit Committee has decided to have a review on the Code of Ethics annually. However, there may be a review in due time following a significant amendments or cancellations.

7. Effective Date The Code of Ethics is in effect from 13th August 2015, 015, which is the day that it has been approved by the Board of Directors.

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CODE OF ETHICS

Sanko Diecasting (Thailand) Plc.

Agreement of Understanding “Code of Ethics”

Sanko Diecasting (Thailand) Public company Limited.

1. I have received and read the “Code of Ethics” 2. I have acknowledged and will abide by the “Code of Ethics” of the Company as the principle guidelines in my work.

Sign ............................................................... ( ) Position: ……………………………………….. ……………………………………

Staff ID: .................................................. .........................................................

Date: .............................................................. .......................................

t code of conduct Remarks: If you require further assistant or explanation about the content of the - For Directors and Managers, rs, please contact the Company Secretary TEL. 02 02-6122311 - For members of staff, please contact the Human Resource Department TEL. 038-961877-80 038 EXT 131

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