Legal and corporate compliance

Basic Approach to Corporate Ethics and Compliance
Hamamatsu Photonics Group Basic Policy of Sustainability and Code of Conduct
Compliance enhancement framework
Instilling a compliance mindset
Whistleblower program
Anti-Corruption
Hamamatsu Photonics Anti-Corruption Policy
Anti-competitive practices
Prohibition of insider trading
Elimination of ties with antisocial forces
Prevention of unlawful exports
Transparency regarding taxation

Basic Approach to Corporate Ethics and Compliance

Guided by the Basic Policy on Corporate Governance, Hamamatsu Photonics has set forth the Basic Approach to Corporate Ethics and Compliance. This statement is posted on the Company’s internal website so that all employees can familiarize themselves with it.

Basic Approach to Corporate Ethics and Compliance was drafted by the president and CEO of Hamamatsu Photonics. The Company is in the business of light, and much about the nature of light remains unanswered. To pursue unknown and unexplored realms, each and every Hamamatsu Photonics group's employee must harbor a burning desire to know the truth. And because a company is the sum of the actions of its people, we expect of every employee a commitment to compliance and respect for human rights, as well as a determination to observe both the letter and the spirit of the law and international rules.

By organizing itself as a corps of employees with a strong sense of ethics, Hamamatsu Photonics aims not only to secure stable management but also to grow and prosper as an enterprise that earns the trust of stakeholders.

Basic Approach to Corporate Ethics and Compliance

Hamamatsu Photonics Group Basic Policy of Sustainability and Code of Conduct

Hamamatsu Photonics has established its Basic Policy of Sustainability, which it discloses to the public. The Company also sets forth its Corporate Code of Conduct, with which every employee is expected to be familiar.

Hamamatsu Photonics Group Basic Policy of Sustainability

Hamamatsu Photonics Group Code of Conduct

Compliance enhancement framework

The Company, led by the Legal and Compliance Department, works tirelessly to ensure that all employees are familiar with its compliance framework. In addition, the Internal Audit Division confirms and strives to improve the awareness of employees while holding interviews with department leaders to confirm the status of enhancement and implementation of the compliance framework. Based on the results of compliance audits, the Internal Audit Division encourages departments and sections that have not taken up educational opportunities about compliance, whether within the Company or from external providers, to pursue in-house training. The Legal and Compliance Department has created a framework for constantly providing compliance education.

【Officer in charge of compliance】
Koichi Nagumo（Executive Officer, Deputy Chief of Global Management and Planning General Headquarters）

Instilling a compliance mindset

To enhance employees’ awareness of compliance issues, Hamamatsu Photonics regularly posts information on the Company’s approach to corporate ethics (compliance) on its internal website, as a call to attention for employees.

In addition, we continue to implement the following compliance mindset activities.

・Freshly hired employees and career-track employees in their third year of employment are provided compliance education.

・Suitable compliance training is also provided in tandem with audits by the Internal Audit Department.

・An awareness survey implemented for all employees every year to encourage their understanding of various regulations and compliance. The company investigate the state of unfair business practices through this survey.

・Distribution of compliance email magazine to all employees.

Whistleblower program

It is the responsibility of each and every employee to move compliance activities forward. If a misstep is spotted, the Company’s basic approach is to resolve the matter within the chain of management. Such resolution may not always be possible, however, and in preparation for such cases the Company has established a whistleblower program. The contact points for the whistleblower program are the Audit & Supervisory Board, the General Affairs Department, the Human Resources Department, and the Legal and Compliance Department.

From the moment someone comes forward with an allegation, the Company takes prudent steps to maintain the secrecy of all personal and other information about the whistleblower, to protect the whistleblower from suffering any kind of disadvantage and abuse of rights due to his or her act of whistleblowing. When a whistleblowing event occurs, the contact point for the whistleblower, which is either the Audit & Supervisory Board, the General Affairs Department, the Human Resources Department, and the Legal and Compliance Department, confers with officer, who is responsible for whistleblower matters. The opinions of attorneys and other outside specialists may also be solicited as necessary. These parties work together to investigate the matter in a fair and impartial manner. If the allegation of an illegal act is found to be true, disciplinary action is taken in accordance with the Employment Regulations.

The number of reports received through Whistleblower program is disclosed in the Governance section of ESG data.
ESG data

【Example of report content】
Illegal provision of benefits, bribery, fraud, unfair transactions, involvement with anti-social forces, criminal acts, harassment, human rights violations, content that violates laws and public interests, etc.

Hamamatsu Photonics Group Compliance Hotline

Anti-Corruption

Under the “Hamamatsu Photonics Group Code of Conduct,” our group pledges to prevent all forms of corruption, including bribery and graft. This pledge is at the very heart of our business, as we announced it in August 2017 when we signed the United Nations Global Compact (UNGC). Furthermore, the “Hamamatsu Photonics Anti-Corruption Policy” (“Policy”) clearly states that all forms of corruption are prohibited and that an internal system to prevent such corruption must be established. Overseas subsidiaries have also established internal regulations regarding anti-corruption.

Hamamatsu Photonics Anti-Corruption Policy

Prohibition of bribery and corruption
Hamamatsu Photonics aims to grow and develop as a sound and trustworthy company by requiring all officers and employees to conduct corporate activities with a high sense of ethics, and prohibits all forms of corruption such as bribery, excessive gifts and entertainment, extortion, embezzlement, collusion, breach of trust, conflict of interest, cartels, money laundering, etc.
We do not accept or provide bribes of any kind, directly or indirectly, to domestic and foreign public officials, quasi-civil servants, and other business partners (hereinafter collectively referred to as "Business Partners"). We also will not accept or provide unfair gifts, entertainment, benefits, or other benefits that exceed the socially acceptable norms.
Small payments (facilitation payments) made to public officials and quasi-civil servants for the purpose of facilitating or expediting routine administrative procedures are prohibited unless expressly permitted by the laws and regulations on the prevention of corruption in the relevant country or region.
Compliance with national laws and regulations
We comply with laws and regulations related to the prevention of corruption applicable in the countries and regions in which we operate.
Organizational and management system development
Under the responsibility of the officer in charge of compliance, we appropriately establish internal regulations on the prevention of corruption and the departments in charge. In addition, we limit gifts and entertainment given/received from Business Partners to a reasonable extent and establish a system for reporting these acts to the company in advance to appropriately manage records.
Additionally, we will report the status of our efforts to prevent corruption to the Board of Directors as appropriate.
Ensuring effectiveness
We will monitor whether our group is in compliance with the Policy and related regulations, as well as the effectiveness of such Policy and related regulations through internal audits, awareness surveys, risk analysis, etc.
In addition, we will regularly provide education and training to officers and employees on the prevention of corrupt practices, such as the prohibition of bribery and the dissemination of the whistleblowing system.
Whistleblowing system
We have established a whistleblowing system and accept reports of corrupt acts, including bribery.
We thoroughly protect whistleblowers so that they are not disadvantaged by making reports, and strive to detect corrupt acts early and respond appropriately.

Established：October 1, 2025

In accordance with the Policy, Hamamatsu Photonics has implemented "Anti-Bribery Regulation" and guidelines outlining detailed standards within the company and is promoting anti-corruption initiatives.

We also regularly conduct training for officers to ensure that they are aware of and understand the importance of anti-corruption. (May 2022, August 2025)

In FY2025, no violations of or sanctions against Hamamatsu Photonics or its subsidiaries occurred with respect to bribery.

Anti-competitive practices

Prohibiting the restriction of free competition is a core principle of the Company’s business. As part of our commitment to stakeholders, we direct all employees to make fair dealing and fair competition integral to our business activities.

In FY2025, no legal actions were taken against Hamamatsu Photonics in connection with any anti-competitive action, antitrust case or monopolistic behavior.

Prohibition of insider trading

The Corporate Code of Conduct of Hamamatsu Photonics clearly prohibits insider trading. The Company establishes regulations on management of inside information and ensures that all employees are familiar with them.

To provide all investors with a clear understanding of its business activities, Hamamatsu Photonics conducts a vigorous program of investor relations (IR). As it does so, the Company takes prudent steps to prevent unfair disclosure. Hamamatsu Photonics suspends IR activities during the silent period between the quarterly closing of accounts and the announcement of quarterly results. We also caution related parties against disclosure of insider information and take care to practice fair disclosure at all times in conducting IR activities.

Elimination of ties with antisocial forces

Hamamatsu Photonics understands that society expects and demands that it must eliminate all relationships with organized crime and other antisocial forces. The Company’s Corporate code of conduct clearly mandates the refusal of all relationships with any such persons or groups, and this information is circulated to all employees.

The Company also maintains close working relationships with local police and related organizations and strives to stay informed about antisocial forces.

Prevention of unlawful exports

Overseas sales account for approximately 70% of the net sales of Hamamatsu Photonics. Among those products are items capable of being applied or transferred to conventional and mass destructive weapons. Under the circumstances, the Company pays scrupulous attention to export control. Specifically, we stipulate internal compliance program on export control and have established an exclusive unit, the Export Control Group of Logistics Management Department, with overall responsibility for internal export control. In addition, the Company actively conducts not only export control judgment but also relevant information collection, internal training (more than 40 trainings a year for each department and each hierarchical level), annual audit and actions in partnership with public agencies to craft a robust framework for compliance and appropriate handling of export control.

Transparency regarding taxation

Hamamatsu Photonics has established Hamamatsu Photonics Group Basic Policy of Sustainability and complies with all related laws, regulations and international rules, both in letter and in spirit. All employees are expected to conduct operations based on a strong sense of ethics. With respect to taxation, the Company strictly abides by the laws, regulations and rules of each country and region, in the spirit of our Basic Policy of Sustainability to pay due taxes in accordance with the content of its business activities.

【Officer in charge of finance, accounting and tax】

Kazuhiko Mori （Director, Senior Executive Officer and Chief of Finance and Accounting General Headquarters）

Legal and corporate compliance

Basic Approach to Corporate Ethics and Compliance

Hamamatsu Photonics Group Basic Policy of Sustainability and Code of Conduct

Compliance enhancement framework

Instilling a compliance mindset

Whistleblower program

Anti-Corruption

Hamamatsu Photonics Anti-Corruption Policy

Anti-competitive practices

Prohibition of insider trading

Elimination of ties with antisocial forces

Prevention of unlawful exports

Transparency regarding taxation

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