Yokohama Rubber Group Action Guidelines (Excerpt)

We shall conduct corporate activities with a high degree of transparency and practice proper disclosure of information.

Basic stance of the Yokohama Rubber Group

1. We shall conduct corporate activities with a high degree of transparency, in keeping with our Corporate Philosophy.
2. We shall make effective use of our corporate assets and heighten our corporate value.
3. We shall make systemic arrangements for ever-vigilant monitoring of risks surrounding the Yokohama Rubber Group, deal promptly with such risks, and constantly review these arrangements.
4. We shall establish standards for business processing and see that they are rigorously applied for correct performance of such processing.
5. We shall practice timely and appropriate disclosure of information on our business results, financial position, and business activities to our stakeholders, and engage in open and fair communication with them.

Putting our basic stance into practice – our action

1. We shall treasure the tangible and intangible assets of the Yokohama Rubber Group, including our reputation and brand, and strive to heighten our corporate value.
2. We shall exclude any and all ties with anti-social forces.
3. We shall be on guard against risks in our midst that could lead to disasters, scandals, and accidents, and deal promptly and appropriately with any related occurrences.
4. We shall obtain personal information on our customers, third parties, our employees, and other persons as well as confidential information on our customers and third parties, only by legitimate methods. In addition, we shall strictly manage any such information, utilize it only within proper scope, and carefully protect it.
5. We shall properly manage exports in accordance with the laws and regulations in the host countries and regions.
6. We realize that the pool of information acquired through our work includes some important undisclosed information otherwise known internally or only within the other organization. We shall properly manage all such information. We shall not engage in any buying or selling of stock etc. using such inside information.

Yokohama Rubber Group Competition Law Compliance Policy

1. Observance of this Policy
   1.1 The Yokohama Rubber Co., Ltd. and the respective companies of the Yokohama Rubber Group(including domestic and overseas companies; hereinafter collectively referred to as the "Yokohama Rubber Group") hereby declare, and officially announce, to observe the "Yokohama Rubber Group Code of Conduct".
   1.2 The Yokohama Rubber Group will familiarize its directors and employees (collectively, "Members") of the "Yokohama Rubber Group Code of Conduct" and this Policy, as well as encourage Members to observe the same through education and disciplinary programs, and manage and supervise Members on their observance of the same.
2. Prohibition of cartel and other acts of competitive restriction
   2.1 Members shall understand that cartel and other acts that restrict competition ("Prohibited Acts") are harmful acts that obstruct efficient economic activities and are acts that will inflict brutal loss on the Yokohama Rubber Group, and shall refrain from engaging in such Prohibited Acts whether in Japan or other countries.
   2.2 The Prohibited Acts include, but are not limited to, the following acts.
   2.2.1 Prohibition of cartel and information exchange with competitors Members must not reach any agreement with competitors regarding price, bid rigging (adjustment of orders), production/sales volume, sales territory, or assignment of customers. Furthermore, Members must not exchange information on prices, or exchange information regarding other matters and secrets which are important in competing with competitors. Exchange of information is prohibited in any manner or form, including by way of written agreement, verbal agreement, or unspoken agreement.
   2.2.2 Restriction of resale price Members must not restrict business partners from freely deciding their selling price such as by forcing business partners to sell the products of the Yokohama Rubber Group at designated prices, or imposing economic disadvantage on business partners that refuse to sell products at designated prices.
   2.2.3 Transactions with tie-in provisions Members must not conduct transactions by imposing conditions that would unfairly restrict the business activities of business partners such as by unfairly restricting sales outside the designated territory, or designating the selling method and causing business partners to observe such selling method without due cause.
   2.2.4 Dumping Members must not sell products and services at unjustifiably low prices that disregard profit.
3. Contact with competitors
   3.1 As a general rule, Members shall not contact competitors irrespective of the country or territory where the competitor is located, and irrespective of the means or method including by way of meeting, interview, phone, fax or email.
   3.2 If it is inevitable to hold a meeting with a competitor, Members to participate in the meeting shall obtain the prior approval of the approver regarding the holding of and participation in the meeting, and, after the meeting is held, report the agenda of the meeting and other necessary information to the approver. The approver will be prescribed in the "Yokohama Rubber Group Competition Law Compliance Rules" ("the Rules").
4. Membership in an industry group
   4.1 No business division or subsidiary of the Yokohama Rubber Group shall become a member of an industry group, irrespective of the country or territory where the industry group is located, unless a prior approval is obtained by taking the procedures set out in the Rules.
5. Measures to be taken in the occurrence of Prohibited Acts
   5.1 When a Member discovers or learns of the possibility that a Prohibited Act has been conducted, such Member shall use the Whistle-blowing System and notify the Whistle-blowing Hotline.
   5.2 The Yokohama Rubber Group will impose strict disciplinary action against any violator of this Policy based on its Work Rules and other internal rules and regulations.

Notes: This policy was approved and enacted at the board of directors meeting on July 28, 2017.

Yokohama Rubber Group Anti-Bribery Policy

1. Observance of this Policy
   1.1 The Yokohama Rubber Co., Ltd. and the respective companies of the Yokohama Rubber Group (including domestic and overseas companies; hereinafter collectively referred to as the "Yokohama Rubber Group") hereby declare, and officially announce, to observe the "Yokohama Rubber Group Code of Conduct".
   1.2 The Yokohama Rubber Group will familiarize its directors and employees (collectively, "Members") of the "Yokohama Rubber Group Code of Conduct" and this Policy, as well as encourage Members to observe the same through education and disciplinary programs, and manage and supervise Members on their observance of the same.
2. Prohibition of bribery
   2.1 Members must not offer, promise or provide monies or other benefits ("bribes") to government employees, foreign government employees, officers and employees of public institutions, state enterprises or government-linked companies, officers or employees of private companies subject to commercial bribery, or any other person who may become the object of bribery (collectively, "Government Employee, etc.") with the purpose of gaining unjust profit through the performance or non-performance of official duties or services, or which may be interpreted as being for such a purpose. The offer, promise or provision of bribes described above includes any indirect offer, promise or provision that is made through any third party including professionals who offer advice or engage in negotiations on our behalf, trading firms, and distributors.
   2.2 When a Member receives a request for a bribe from a Government Employee, etc., such Member shall refuse the request.
   2.3 Even when a Member is offered a bribe in a country where the offering of facilities to an employee of a private company does not constitute bribery, such Member shall not receive such bribe ("acceptance of bribe"), and shall refuse the offer.
3. Points to consider upon expending monies, etc.
   3.1 Expenditure based on the reasons set out in each of the following items that is to be made under circumstances where it would not be misunderstood as being for the bribe described in Paragraph 2.1 must be made pursuant to proper financial and accounting procedures. When the expenditure is made within a reasonable range upon obtaining the approval of the authorized approver, as a general rule, such expenditure will not be prohibited.
   3.1.1 Social costs such as travel expenses and meal expenses involving a Government Employee, etc., support money to be paid for regional activities, donations to organizations, and other social expenses that are permitted under applicable laws.
   3.1.2 Costs required for conducting activities to gain the consumers' understanding of the products and services of the Yokohama Rubber Group that are permitted under applicable laws.
   3.1.3 In cases where it is essential to hire an attorney, consultant or any other professional (collectively, "Agent, etc.") upon dealing with a Government Employee, etc. due to the business practice of the country or territory where the deal is to be made, fees to be paid to the hired Agent, etc.
   3.2 Yokohama Rubber Group will create, organize and store the following records so that, when expenditure is made based on any of the reasons set out in Paragraph 3.1.1, Paragraph 3.1.2, or Paragraph 3.1.3, such records can be readily disclosed in response to inspections by public institutions.
   3.2.1 Records which certify that the expenditure was made pursuant to proper financial and accounting procedures and upon obtaining the approval of the authorized approver.
   3.2.2 In the case of Paragraph 3.1.3, grounds demonstrating that the services consigned to the Agent, etc. were appropriate and the service fee was reasonable, and a list of the hired Agents, etc.
4. Points to consider upon receiving monies, etc.
   4.1 Members must not receive facilities, or request or promise the reception of facilities, in relation to their job duties excluding the case permitted under Paragraph 4.2.
   4.2 Members may receive facilities upon obtaining the approval of the authorized approver.
5. Measures to be taken in the occurrence of risks
   5.1 When a Member receives a request for a bribe from a Government Employee, etc., or discovers or learns of a case where a bribe was actually offered, promised or provided, or of the possibility thereof, such Member shall promptly use the Yokohama Rubber Group's Whistle-blowing System and notify the Whistle-blowing Hotline. The same shall apply to cases where such Member discovers or learns of a case where a bribe was accepted, or of the possibility thereof.
   5.2 The Yokohama Rubber Group will impose strict disciplinary action against any violator of this Policy based on its Work Rules and other internal rules and regulations.

Notes: This policy is intended to prohibit violations of various bribery regulations, including domestic and international bribery offenses.

Notes: This policy was approved and enacted at the Board of Directors meeting on July 28, 2017.