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TAMURA CORPORATION
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Compliance & Risk Management
The Tamura Group is maintaining and strengthening its framework for compliance and risk management in order to ensure compliance with corporate ethics and laws and regulations and to be able to address a wide range of management crises effectively.

Compliance framework
Tamura is maintaining and strengthening its functions to secure compliance with laws and regulations and to take action accordingly with the establishment of the Compliance Committee, the Compliance Promotion Consultation Committee, and the Compliance Generalization Group, an organization independent of Tamura's business operational divisions.

Compliance Committee
The Compliance Committee was established in FY2006 with the company president as chair. Attended by outside experts, the committee convenes twice a year to look into the state of the compliance framework and into the planning and implementation of compliance activities, as well as to deliberate and issue resolutions on compliancerelated issues and agenda items, execute corrective measures, and issue the necessary recommendations to relevant business divisions and sections.

Compliance Promotion Consultation Committee
The Compliance Promotion Consultation Committee was set up in FY2006, chaired by the general manager of the Compliance Generalization Section. In the organization, seven compliance units have been formed to cover the entire Tamura Group, with a promotion officer representing each unit. The committee meets four times a year as a general rule, to plan and deliberate on activities that are necessary to boost the establishment and dissemination of the compliance framework throughout the Group.

In-house Compliance Hotline
As a mechanism for counseling and reporting illegal activities, the In-house Disclosure Regulations have been established and an In-house Compliance Hotline has been set up for access to the Compliance Generalization Section via Intranet or a dedicated phone line. Reporting can be made anonymously and any action detrimental to the interests of the reporting or cooperating party is prohibited to encourage and solicit information that will lead to reinforcement of the compliance framework and the early detection of internal risks.
In order to enhance the protection and convenience of the reporting party, we have set up the Tamura Group Helpline in April 2010. It is a reporting contact point outside the company used a long with the company Intranet.

Information Securit
In FY2008, In formation Security Basic Policy and Information Security Management Regulations were established to ensure the appropriate and timely disclosure of information, as well as for the protection and management of information (including both corporate and personal data), in accordance with the type and nature of the information. Information-related risk management is being implemented under the above-mentioned policy and regulations. In addition to technical security measures, including network security protection, data access control, and restriction on the use of external storage, ID card authentication systems have been introduced as physical security measures.

Risk management
Risk Management Regulations
In order to address risks that can seriously affect business management, Risk Management Regulations have been established and implemented to streng then the risk management system of the entire Tamura Group. The fundamental principles underlying these regulations are swift, objective, and concerted action by management and employees to address management-related risks and, if human lives are threatened, the top priority is placed upon the protection and rescue of personnel. Furthermore, “Alarm Escalation” items, divided into Level A and Level B, have been established, corresponding to the level of risk and the scale of impact.

Web-based Alarm Escalation Notification System
For a speedy and accurate report on Alarm Escalation items under the Risk Management Regulations to the management or the risk management officer, the Web-based Alarm Escalation Notification System has been set up on the Tamura Intranet. In FY2009, there were 8 Level A reports and 37 Level B reports, which were all handled and processed appropriately, corresponding to the situation of each case.

Response to Security Export Controls
The Tamura Group has always practiced strict export control based on the Foreign Exchange and Foreign Trade Act, in order to ensure that our products and technologies are not converted into arms or weapons for use abroad. Since the integration of the Tamura Group in April 2010, we have launched new export control systems in continuing our effort.
In August 2010, the Tamura Group affiliates across the areas in South China and East China gathered for a training to implement export controls under the laws and regulations of China as well as the Tamura Group's policy. We are working to ensure implementation of export controls by the entire group through systematic continuation of such employee training.

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