COMPLIANCE

1.Objectives, etc.

This Code of Conduct is designed to make the directors as well as every staff member of EJEC recognizes that they are principal players in the achievement of compliance-conscious business management so that the Code of Conduct of the parent company, E-J Holdings, is upheld as the higher code for all group companies to ensure healthy business management and the proper as well as smooth business operation of EJEC as a consultancy firm.

2.Code of Conduct

1. Officers and staff members must fully understand the Mission of EJEC as a consultancy firm related to the development of social capital, etc. and must seek to achieve the healthy and sustainable development of the company and its social responsibility by means of respecting human rights and behaving with good social sense and high ethical standards in addition to properly understanding and implementing the corporate philosophy and management policies and observing the laws and company rules.

2. As employees of a civil engineering consultancy firm, the officers and staff members must properly understand and recognize the “Code of Ethical Practice” and “Guidance to Enlighten Professional Ethics” stipulated by the Japan Civil Engineering Consultants Association and make constant efforts to always follow them. Similarly, anyone in a technical position must follow the “Code of Ethics for Civil Engineers” stipulated by the Japan Society of Civil Engineers while anyone with the certification of professional engineer must follow the “Code of Ethics for Professional Engineers” stipulated by the Institution of Professional Engineers, Japan (IPEJ).

3. The directors must fulfill their duties as officers as stipulated by the Companies Act and must not conduct any act of disloyalty or act of conflicting interest, etc. They must also be aware of their role in the achievement of “compliance-conscious business management” whereby the social responsibility of the company must be met while trying to increase the corporate value based on the corporate philosophy and management policies advocating the “E-J Global Challenge” as the basic concept in the Medium-Term Business Plan for the E-J Group formulated in June, 2007 and must endeavor to put the corporate ethics into practice.

4. When a situation contradicting this Code of Conduct arises, the President must explicitly indicate the stance to honestly try to solve the problem or situation from within or outside the company from his/her own point of view as the chief executive officer and should make sincere efforts to investigate the cause and to prevent any recurrence. The President as the top executive must execute the swift disclosure of accurate information and fulfill his accountability while conducting the appropriate punishment of managers or supervisors, including him/herself, related to the problem, etc. in question and publicly announce the details of such punishment to clarify the management responsibility.

3.Subject Matters for Compliance

Officers and staff members must not only comply with the laws and internal rules in every situation of corporate activities but also be aware of and comply with the following concrete matters on their own responsibility.
1. Establishment of an internal control system
2. Respect for human rights
3. Creation of a healthy work environment
4. Impartial and lawful execution of the work
5. Prohibition of any act contradicting public and company interests
6. Appropriate handling of company information and protection of personal information
7. Prohibition of gifts and entertainment
8. Maintenance of the accuracy of financial reports and appropriate management of company assets
9. mplementation of proactive environmental conservation efforts
10. Maintenance of authority and quality as a group of professional engineers
11. Elimination of anti-social forces
12. Compliance with laws relating to intellectual property rights
13. Active participation in activities contributing to society