Our parent company, MinebeaMitsumi Inc., is committed to be not only an organization that pursues profits through

free and fair competitions  but also an entity that  broadly  provides  usefulness  to the society.  Under these circumstances,

compliance (observance of laws and ethical principles) is regarded as an important element of business management.

In addition,   our  parent  company  is  conducting  business  transactions  in a  fair  and  sincere  manner towards  its

stakeholders from the viewpoint of corporate governance. In other words,MinebeaMitsumi Inc. has duties to fulfill its social

responsibility  and  improve  its  corporate value not only by complying  with  laws and  regulations but also,  as a corporate

citizen, by conducting appropriate and fair business management based on corporate ethics.

MinebeaMitsumi Group  has upheld five rules as  basic management principles  :  "Be a company of which employees

are proud to be a part",  "Gain the trust of customers",  "Meet the expectation of shareholders",  "Be welcomed by the local

community",  and  "Contribute to the international community".  It has been clarified that an earnest and  serious attitude

toward  stakeholders  such as   shareholders,  customers,  business partners,  employees,  government  agencies,  and  the

society is a fundamental  building block of  MinebeaMitsumi business.  MinebeaMitsumi Group  has  also strived to achieve

highly transparent management.

Since the foundation in 1951,  MinebeaMitsumi Inc., has been one of the most active forerunners in promoting global

operation presence.  Through that period,  compliance with laws has been implemented as a matter of course in our group

both  domestically  and  internationally.   MinebeaMitsumi  Group’s  efforts to  promote  employment  and  foster  human

resources  have  also  contributed  to local  communities.  Furthermore,   MinebeaMitsumi  Group  have  fulfilled  a  social

responsibility  through  environmental  protection  efforts such as  obtainment of  ISO14001 for all  our  production  sites

around the world as well as through  efforts to promote labor safety  and  health in which we have obtained  ISO45001 for

factories mainly in Asia.

Consequently, our parent company has declared a commitment to continuously strive to understand corporate ethics

and  applicable laws,  harmonize with society,  and  achieve  sustained  improvement  of  corporate value  through fair and 

appropriate business management by ensuring implementation of MinebeaMitsumi Group Code of Conduct.

MinebeaMitsumi Group (Thailand),  as part of  MinebeaMitsumi  Global Group,  acknowledges and  shares  the  same

commitment. Moreover, we have a commitment to global citizenship which includes growing our company in a strong and

sustainable  way,  preserving  and  protecting  our  environment,   promoting a safe  and  healthy  work  environment  and

treating  people  with  dignity and  respect.   To put such commitment into practice, we have established and implemented

MinebeaMitsumi Group (Thailand) Code of Conduct. To ensure unity and solidarity with our parent company, our Code of

Conduct is revised to align and be in line with  MinebeaMitsumi Group Code of Conduct.

Each director and employee of our group is required to fully comprehend the purpose and comply with MinebeaMitsumi

Group (Thailand) Code of Conduct.

July 12, 2025
MinebeaMitsumi Group (Thailand)
President and Director
Yoshihiro Sakanushi

1. LABOR
          The MinebeaMitsumi Group (Thailand) is committed to upholding the human rights of employees, and to treating

them  with  dignity and respect.  All  companies  within  MinebeaMitsumi Group (Thailand) shall adhere to the following

standards regarding use of labor :

(1) Freely Chosen Employment

Forced,  bonded, indentured, or involuntary and inhuman prison labor shall not be used.  All work shall be voluntary,

and  MinebeaMitsumi  Group (Thailand)  employees  shall  be  free to leave upon  reasonable  notice  in  compliance  with

applicable law, regulation, and contractual agreement. MinebeaMitsumi Group (Thailand) employees shall not be required

to hand over government-issued identification, passports, or work permits as a condition of employment.

(2) No Child Labor

Child labor shall not to be used in any stage of manufacturing. The term "child" refers to any person employed  under

the age of 15,  or under  the age for completing compulsory education,  or under the minimum age for employment  in the

country, whichever is greatest.  MinebeaMitsumi Group (Thailand)  supports the use of legitimate workplace apprenticeship

programs  which comply  with  all laws and regulations.  MinebeaMitsumi Group (Thailand) employees under the age of 18

shall not perform hazardous work and may be restricted from night work with consideration given to educational needs.

(3) Discrimination

The   MinebeaMitsumi  Group  (Thailand)  is  committed  to  a  workforce  free  of  harassment  and  discrimination.

Companies within MinebeaMitsumi Group (Thailand) shall not engage in discrimination based on race, color, age, gender, 

sexual orientation,  ethnicity,  disability,  religion,  political affiliation,  union membership  or  marital  status  in hiring and

employment practices such as promotions, rewards, and access to training. In addition, employees or potential employees

should not be subjected to medical/pregnancy tests that could be used in a discriminatory way.

(4) Harsh or Inhumane Treatment

Companies  within  MinebeaMitsumi Group (Thailand)  shall not allow  any harsh and  inhumane treatment, including

any  sexual  harassment,  sexual  abuse,  corporal  punishment,  mental  or physical coercion or verbal abuse of employees,

nor shall the threat of any such treatment be allowed.

(5) Minimum Wages

Compensation paid to employees  shall  comply with  all  applicable wage laws, including those relating to minimum

wages, overtime hours, and legally mandated benefits. Any disciplinary wage deductions are to conform to applicable law

and regulation. The basis on which employees are paid shall be clearly communicated to them in a timely manner.

(6) Working Hours

Work  weeks are not to exceed the maximum set by applicable law and regulation. Employees should be allowed at

least one day off per seven-day week.

(7) Freedom of Association

The  MinebeaMitsumi Group  (Thailand)  respects the rights of its employees to associate freely,  join labor unions,

seek representation, and or join workers' councils in accordance with applicable law and regulation. Employees shall be

able to communicate openly  with  management  regarding  working conditions  without  fear  of reprisal,  intimidation,

or harassment.

2. HEALTH AND SAFETY

            The MinebeaMitsumi Group (Thailand) recognizes that the quality of its products and services, consistency of

production,  and  employee  morale  are  enhanced  by a safe and healthy  work environment.  All  companies  within

MinebeaMitsumi Group (Thailand) shall adhere to the following standards regarding health and safety :

(1)  Machine Safeguarding

            Physical guards, interlocks and barriers for machinery used by employees shall be provided where appropriate,

and shall be properly maintained.

(2)  Industrial Hygiene

            Employee  exposure  to chemical,  biological and  physical  agents shall be identified, evaluated, and controlled.

When  hazards  cannot be  adequately  controlled  by  engineering and  administrative  means,  employees  shall be 

provided with appropriate personal protective equipment.

(3)  Safety

            Employee  exposure  to  workplace  safety  hazards  shall be identified,  evaluated,  and  controlled  through proper

design,  engineering  and  administrative controls,  preventative maintenance,  and safe work procedures.  Where hazards

cannot  be  adequately  controlled by these  means,  employees  shall  be  provided  with  appropriate  personal protective

equipment.

(4)  Emergency Preparedness and Response

            Emergency  situations  and  events  shall be identified and assessed,  and their impact  minimized by implementing

emergency response and recovery plans and procedures.

(5)  Occupational Injury and Illness

Procedures and systems shall be implemented to manage, track and report occupational injury and illness, including

provisions to : 

a) encourage worker reporting ; 

b) classify and record injury and illness cases ; 

c) provide necessary medical treatment ; 

d) investigate cases and implement corrective actions to eliminate their causes ;

and, 

e) facilitate return of employees to work.

(6)  Physically Demanding Work

            Employee exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged

standing,  and highly repetitive or forceful assembly tasks shall be identified,  evaluated and controlled.  Employees shall be

provided with appropriate equipment to perform such tasks.

(7)  Dormitory and Canteen

            Workers  shall  be  provided with clean toilet facilities,  access to potable  water and  sanitary food preparation and

storage facilities. Worker dormitories provided by the  MinebeaMitsumi Group (Thailand) shall be clean,  safe,  and provide

emergency egress,  adequate heat and ventilation,  and reasonable personal space.

3. ENVIRONMENT

            The MinebeaMitsumi Group (Thailand)  recognizes that environmental responsibility is integral to producing world

class  products.  In our operations,  adverse effects  on  the  environment  and  natural resources shall be  minimized  while

safeguarding  the  health and  safety of the public.  All companies within MinebeaMitsumi Group (Thailand) shall adhere to

the following standards regarding the environment :

(1) Product Content Restrictions

            All products shall adhere to applicable laws,  regulations,  and  customer  requirements  regarding  prohibition  or

restriction of specific substances, including labeling laws and regulations for recycling and disposal.

(2) Chemical and Hazardous Materials

            Chemical and other materials posing a hazard if released to the environment shall  be  identified and managed to

ensure their safe handling, movement, storage, recycling or reuse, and disposal.

(3) Wastewater and Solid Waste

            Wastewater  and  solid  waste  generated  from operations,  industrial processes,  and sanitation facilities shall be

monitored, controlled, and treated as required by applicable law and regulation.

(4) Air Emissions

            Air emissions of  volatile  organic chemicals,  aerosols,  corrosives,  particulates,  ozone  depleting  chemicals and

combustion by-products generated from operations shall be characterized, monitored, controlled, and treated as required

by applicable law and regulation.

(5) Environmental Permits and Reporting

            All environmental permits and registrations required by applicable law and regulation shall be obtained, maintained,

and kept current. The operational and reporting requirements of all permits and registrations shall be followed.

(6) Pollution Prevention and Resource Reduction

            Waste of all types, including water and energy, are to be reduced or eliminated to the extent practicable at the

source or by practices such as modifying production, maintenance, and facility processes, materials substitution, conservation,

recycling, and or re-using materials.

4. ETHICS AND BUSINESS PRACTICE

            To meet our social responsibilities and to increase our corporate value, The MinebeaMitsumi Group (Thailand) has to uphold the highest standards of ethics including :

(1) No Corruption, Extortion, or Embezzlement

            The highest standards of integrity shall be maintained in all business interactions. Any and all forms of corruption, extortion and embezzlement are strictly prohibited. Any such conduct may result in termination and legal action.

(2) Disclosure of Information

            Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices.

(3) No Improper Advantage

            Bribes or other means of obtaining undue shall not be offered or accepted.

(4) Fair Business, Advertising, and Competition

            Standards of fair business, advertising, and competition are to be upheld. Customer information shall be safeguarded.

(5) Community Engagement and International Operation

            Community engagement is encouraged to help foster social and economic development. The MinebeaMitsumi Group (Thailand), as an international corporation, contributes to the development of the community in every country in which we operate by not only complying with the laws and rules of each country, but also by respecting its history, culture and customs.

(6) Protection of Intellectual Property

            The MinebeaMitsumi Group (Thailand) respects intellectual property rights and implements proper measures to protect others' intellectual rights. To protect those rights, the Group also pays full attention to transferring and handling our or others' technologies or know-how.

(7) Import/Export

            Compliance with not only the laws and rules of each country but also all applicable international rules, regulations, and trade agreements shall be maintained when trading products or materials with, or providing technological assistance to, foreign countries. Appropriate management systems and procedures shall be maintained to assure compliance.

(8) Response to Antisocial Forces

            The MinebeaMitsumi Group (Thailand) has no relations with any antisocial forces that may or will pose a threat to the public order and/or safety. At the same time, regarding unreasonable demands, if any, from such forces, without making compromises, the Group shall cooperate with external specialized institutions, including police and lawyers, and deal with such demands in a resolute attitude.

1. ROLE OF THIS CODE OF CONDUCT

            This Code of Conduct is one of the important tools for practicing Compliance based on the company policy. We assure all the stakeholders that, by practices based on the system described below, we will carefully follow the guidelines set out in This Code of Conduct.

2. STRUCTURE OF COMPLIANCE

(1) Chief Officer of Compliance

            President and Director of NMB-Minebea Thai Ltd. takes a role of the chief officer of the compliance system of MinebeaMitsumi Group (Thailand).

(2) Compliance Committee

            The Compliance Committee, a body to promote Compliance including this Code of Conduct, is established directly under President and Director of NMB-Minebea Thai Ltd.

            The Compliance Committee assumes the operation of this Code of Conduct, approved by the Board of Directors, and takes a role of making decisions to address urgent requirements when a serious violation of the compliance occurs. A secretariat for the Compliance Committee shall be the Compliance Office. The secretariat functions as an organ to execute and promote compliance measures approved by the Compliance Committee. It also functions as the secretariat for the body that makes decisions to address urgent requirements when a serious violation of the compliance occurs.

(3) Application to Each Company of Our Group and Supply Chain

            This Code of Conduct is to be circulated to each company of MinebeaMitsumi Group (Thailand). Each company is required to take necessary compliance measures in accordance with this Code of Conduct. Moreover, efforts shall be made to voluntarily observe this Code of Conduct in the MinebeaMitsumi Group (Thailand)'s supply chain, and each company shall request as appropriate that its suppliers and subcontractors agree to and implement this Code of Conduct.

(4) Addition of Detailed Guidelines

            When putting this Code of Conduct into practice, while some detailed guidelines have been already stipulated, new detailed guidelines may be added according to specific requirements. We must comply not only with this Code of Conduct but also with such new detailed guidelines.

(5) Duty to Report

            When you are not sure if your acts or decisions violate this Code of Conduct, it is your duty to consult your superiors, the competent departments or the consultation service separately designated by the Company. Also, when you notice any violation of this Code of Conduct by a director or an employee, you must immediately report to the Compliance Office, Human Resources and Administration Division or the consultation service designated by the Company. We ensure that every aspect of the privacy, such as his/her name and the content of the above-mentioned consultation, will be kept secret. We also ensure that he/she will not be disadvantaged due to such consultation.

(6) Penalty

            In case of violating this Code of Conduct, one will be subjected to disciplinary action according to the company rules. When the act of violation causes damage to the company, he/she may be required to indemnify the company for the loss. One who violates this Code of Conduct for the following reasons will not be exempt from responsibility:

1. Lack of knowledge on laws and regulations.
2. Absence of intention to violate the laws and regulations.
3. Intention to act for the benefit of the company

(7) Education and Training

            Based on this Code of Conduct, education and training concerning compliance are conducted for the following purposes. The employees who are ordered to participate in the training by the Compliance Committee, the secretariat, or an immediate supervisor must not refuse or fail to attend the training without legitimate reasons.

1. To increase the awareness of overall compliance issues such as laws and regulations as well as corporate ethics.
2. To provide accurate knowledge of this Code of Conduct and various office regulations.

(8) Audit

            Each company of our group is required to conduct regular internal audits in accordance with this Code of Conduct to ensure none of the company activities violates the compliance manual. With the cooperation of each related department, the secretariat, according to the specific requirements, is to conduct audit to find out if there is any acts of violation of the compliance within our group. The secretariat is then required to report the result of the audit to the Compliance Committee. It also orders the concerned department/section to correct its inadequate operation if necessary.