We adopt the code of conduct of the Naikai Tug Boat Service, our parent company.
We regard it as our most important tasks to provide safe and consistent service. We ask our employees to further boost customer satisfaction and trust by improving service quality, developing innovative technologies, and pursuing appropriate cost levels.
All members must promote environmental conservation by complying with all relevant environmental laws and regulations, and we ask that you consider the impact of activities on the natural environment, and voluntarily take measures to preserve the environment such as waste reduction, ecosystem preservation, and improvement of environmentally friendly technologies.
All members must comply with laws, regulations and internal rules, and conduct truthful, fair and equitable trading activities in accordance with social norms.
We must select business partners properly and fairly, and in addition to ensuring the reliability of products and services offered by business partners and the stability of their business performance, we must take into consideration CSR (Corporate Social Responsibility) such as compliance with laws and social norms, environmental conservation, prevention of corruption, respect for human rights, and improvement of employment and working environments.
It is prohibited to acquire internal information from other company illegally or improperly, or to use that information for one’s own business purposes or leak it externally.
Personally collecting remuneration or brokerage fees from others in relation to business transactions is prohibited regardless of the reason. However, if proper fees are paid to the company and recorded as company income, it is acceptable even if addressed to an individual.
With regard to employees’ writing articles for magazines, etc. or giving lectures, we will consult with the Administrative Department about whether or not to treat this as relevant to the company’s business activities, and if so, any remuneration belongs to the company.
It is prohibited to utilize business relationships to have other companies or other people, such as trading companies, bear expenses (including entertainment expenses) related to the company’s business.
Also, having another company or a third party bear the expenses for private use is obviously an illegal act and is strictly prohibited.
Please refrain from exchanging gifts and greeting cards, such as in summer and at year-end, unless it is within the scope of social norms and based on personal intention. Please also try to keep rituals related to ceremonial occasions, etc. within the scope of social norms and based on personal intention. We do not accept gifts from subsidiaries or companies that are under our de facto control. If you receive such a gift, please report it to your superior and return the gift to the giver graciously.
The approval of the Board of Directors is necessary when a company officer assumes office as a representative or agent of other company, or a director runs his or her own company. Even when taking office as an officer of another company in a non-representative capacity, the Board of Directors must be notified.
Employees are generally prohibited from taking positions as officers, employees, agents, etc. of other companies or organizations, except when instructed to do so by the company. However, if there are unavoidable circumstances, please notify the Administrative Division and obtain permission from the company.
Serving concurrently at trading partner companies, including as an adviser or consultant to any company with whom we are engaged in business transactions, is generally prohibited as it is likely to cause suspicion of abuse of positon. However, if there are unavoidable circumstances, please notify the Administrative Division and obtain permission from the company.
It is prohibited to utilize one’s position to put pressure on people within the company to deal with a company with which his/her relatives or friends are related. Business transactions should be decided objectively in view of price, service and quality.
We value personal dignity. It is unacceptable to discriminate in word or action against anyone on the basis of gender, age, nationality, ethnicity, race, beliefs, religion, social status, lineage, hometown, occupation, appearance, or disability.
There is zero tolerance for behaviors such as disrespect, mischief, discriminatory treatment, harassment, intimidation, sexual harassment, power harassment and so forth. If you suffer such treatment, please notify the president or general manager of the Administrative Department directly. When the company receives a complaint, we immediately investigate the facts and rectify the situation with sufficient consideration so that the victim does not suffer disadvantageous treatment thereafter.
All of us are independent individuals, but at the same time, we are members of Naikai Tug Boat Service. Thus while our actions on and off the job show our distinctive personality and character, they also influence people’s assessments of Naikai Tug Boat Service. This means we are required to thoroughly consider our behavior inside and outside the company and exercise self-control so as to maintain our self-awareness and dignity as members of Naikai Tug Boat Service.
We recommend that as members of society, our employees voluntarily engage in community activities unrelated to company operations. We view individuals who take the initiative in engaging in social and volunteer activities in a positive light, and believe such activities earn the individual honor and respect.
Employees and company officers are free to carry out political and religious activities based on personal ideas and beliefs. However, political and religious activities on company premises or during business hours are prohibited.
We firmly refuse against any unfair demands from antisocial elements or persons suspected of involvement with them, and prohibit any relationship whatsoever with such persons.
Aim for work-life balance, and strive to create workplaces where every employee can work safely and feel rewarded by their work.
Insider trading is punishable under the Securities and Exchange Law as damaging the fairness of market transactions by conducting securities transactions such as sales of stock, credit, etc. based on corporate information learned in the course of business. Important information on listed companies must be disclosed, and when communicated to the Tokyo Stock Exchange through the TDnet system, posted on the Timely Disclosure Information Website operated by the Stock Exchange etc. at the specified time of disclosure, or when more than 12 hours have elapsed, after notifying two or more news organizations. Transactions carried out prior to release of information invite suspicion of insider trading, so during this time it is important to prevent external leakage of information and strictly forbidden to buy and sell stock, credit, etc. based on that information.
Company officers and employees are responsible for managing information obtained on the job so that it does not leak outside the company. Especially in public places (elevators, washrooms, on trains or other vehicles, eating and drinking establishments etc.), talking about company matters shows immaturity in terms of information management. Handle confidential information appropriately and keep information secure, in accordance with proper procedures, whether it is in document or electronic form. In particular, transferring personal information outside the company is strictly prohibited.
As information technology advances, greater consideration is required for the protection of tangible and intangible intellectual property. It is not permissible to obtain or use other parties’ intellectual property by improper means or without authorization. Do not utilize confidential information developed by others, such as computer software programs, information with restrictions on usage conditions, etc., without paying the requisite fees, or otherwise utilize with copies disregarding the conditions of usage. When quoting a company name or trademark of another company in one of our publications, etc., it is necessary to confirm the correct notation and obtain the company’s consent.
Even after retiring or resigning from the company, do not disclose or utilize confidential information you learned while employed there without the company’s express permission. Corporate information is the property of the company, and arbitrary use by individuals is strictly prohibited.
Company equipment and supplies are lent to company officers and employees as required for the performance of company operations. Their personal use or appropriation is prohibited, and those that do not handle these articles with care will be reprimanded.
If you have any questions about this Code of Conduct, or if you are aware of any violations, please notify your supervisor. Here “supervisor” refers to directors, department managers, and heads of business locations.
Employees who are adversely affecting or harm the company by violating this Code of Conduct or any other company regulations and instructions will be penalized according to laws and company regulations.
Established in February 2008
Revised in September 2010
Revised in November 2014
Revised in September 2017