Introduction

The ADK Group, namely Asatsu-DK Inc. and its group companies, has adopted a code of conduct to ensure that the Group remains aware of its obligations to society and that it willingly acts on them as a responsible member of society. The code of conduct has also been adopted to further increase the Group's corporate value. The executives and the employees of the ADK Group pledge to follow this code of conduct in a conscientious manner so that ADK may warrant greater levels of respect and regard.

I. General provision

The ADK Group operates with a corporate philosophy of zenin keiei, or management by all. The philosophy encourages all executives and employees to exercise creativity, tackle assignments on their initiative and express themselves, as though they were business operators or administrators themselves. It also encourages them to exercise responsible self-governance.

The ADK Group provides communication services and many directly related services to its clients. During the execution of such services, the Group pledges to respect human dignity and human rights. It also pledges to follow laws and public morals so that it can operate in a morally responsible manner.

The ADK Group pledges to operate in a morally responsible manner in its international operations and initiatives as well. It vows to adhere to accepted international rules and national laws and regulations. It also vows to respect local cultures and customs. The Group pledges to promote localization of local business entities and accelerate development in the countries where it operates.

II. Elevation of the company‘s value

The ADK Group shall aim to help its clients to raise the values of their respective brands. It shall also aim to provide high-quality communication services that can contribute to the vitalization and advancement of society. It shall seek to secure continuous growth of the Group's corporate value over the mid to long term while exercising responsible corporate management, respecting the many stakeholders who are involved and working on a relationship with society that is both harmonious and mutually beneficial.

The ADK Group shall work with a spirit that it calls the "6 togethers." It shall seek to learn together, to talk together, to work together, to decide together, to take responsibility together and to empathize together. The Group shall build on that foundation and form teams of communication specialists that demonstrate high levels of creativity, innovation and vitality to advance the quality of the assignments.

III. Adherence to rules and laws, and the establishment of fundamental policies

Corporate activities that are founded on fair competition and responsible transactions

In its corporate activities, the ADK Group pledges to follow fair, competitive practices, conduct responsible transactions and follow the relevant laws and regulations as well as societal rules and morals.

The Group vows to clearly outline the Group's needs, its conditions, the selection process and the reasons for the selection when selecting the entities that it will be working with.

The Group shall manage information in an appropriate manner as an element of its corporate activities. The Group shall respect the confidentiality obligations in regards to the confidential information of its clients and partners. It shall also appropriately and strictly manage information, including any personal information that it may have gained during the execution of duties.

Compliance with societal norms, and achievement of social justice

The ADK Group pledges that all Group executives and employees will advocate social justice, exercise decency and clearly discriminate official business from personal affairs. The Group shall avoid the presentation of gifts, services and entertainment that are outside the realms of societal norms with whom it deals with. It shall also refuse the acceptance of such. The Group shall maintain an extremely transparent relationship with government bodies and authsorities. It shall avoid all transactions and relations with anti-social elements and forces, and shall emphatically refuse the demands and requests of such.

Respect of the employees' diversity, rights and individuality, and the maintenance of an appropriate labor environment

The ADK Group shall respect the human rights of its employees and shall provide an environment that will enable all employees to exercise their managerial perspectives and maximize their inherent individuality and abilities.

The Group shall respect the rules and regulations that govern labor and shall provide a healthy labor environment.

The Group shall avoid all discrimination, including those based on race, religion, nationality, gender, age and disability. It shall objectively evaluate persons on the basis of their merits and on the performance that they demonstrate.

Obligations to the stockholders and stock markets

As a publicly listed company, ADK and the relevant Group companies shall respect the rules and regulations of the relevant stock exchanges. It shall also exercise management that is in the best interest of the stockholders and seek to raise their worth.

The ADK Group shall fully comprehend its obligations as a publicly listed company to provide financial reports that are above suspicion or doubt. The Group shall prioritize integrity in its accounting to ensure such reports. It shall also establish and maintain an appropriate, internal control system to ensure constant improvement.

The ADK Group shall provide and transmit accurate company information at the appropriate times and in a fair manner to the stakeholders to enable the fair valuation of stock value. The Group shall unequivocally avoid insider trading and other transactions that may be construed as such in regards to securities issued by the ADK Group companies or by the parties with whom it deals. In conjunction, it shall establish and maintain the appropriate internal rules and controls and shall thoroughly monitor for such practices.

IV. Eco-friendly practices, and contributions to society

Eco-friendly practices

The ADK Group shall fully recognize the impact that its corporate activities may have on the environment. Accordingly, all Group executives and employees shall promote activities that minimize the impact on the environment.

The ADK Group shall develop and suggest communication methods that address environmental issues when providing communication services to its clients. The Group shall endeavor to help resolve environmental issues through such efforts and more.

The ADK Group's position on activities that contribute to society

The ADK Group shall actively undertake activities that contribute to society within the realm of communications. It vows to work with public groups and organizations, NGOs, NPOs and independent specialists, volunteering and donating ideas and creative works.

The ADK Group shall respect the volunteering spirit of its employees. It shall make efforts to extend their talents and experience in societal contributions and shall supports such activities.

V. Thorough implementation of the code of conduct

The ADK Group shall hold regular educational sessions and seminars to ensure thorough and wide understanding of the code of conduct.

The ADK Group shall promote the implementation of the internal systems, from the perspective of risk management, to prevent actions and behavior that may run contrary to the code of conduct.

The ADK Group shall address any questionable matters that may run contrary to the code of conduct, shall identify the causes and shall prevent reoccurrence in a just, honest manner.

Issued: November 9, 2006
Revised: December 1, 2007