OMRON's CSR Practice Guidelines include guidance for "Competition and Fair Dealing" and "Prevention of Corrupt Practices." Guided by the Corporate Ethics & Business Conduct Committee, OMRON strives to maintain high ethical standards among all OMRON business companies and Group companies to prevent any unfair competition, corrupt practices or illegal behavior.

In fiscal 2010, to ensure avoidance of corrupt practices, OMRON conducted training regarding the Subcontract Act and other compliance-related subjects using e-learning materials in the Corporate Ethics Month.

CSR Practice Guidelines　Competition and Fair Dealing

BASIC POLICY

The OMRON Group strives to act in conformance with principles of fair and free competition, recognizing this as a fundamental ground rule for proper and efficient business activities. The OMRON Group also emphasizes protection of rights for customers and consumers, sound development of the economy, and the independence of individual organizations. Accordingly, the OMRON Group promotes free competition and endeavors to maintain legal, fair and transparent relationships with its distributors, suppliers, customers and, as appropriate, competitors. As for suppliers, we expect their support and cooperation in the OMRON Group's CSR procurement activities.

PRACTICE GUIDELINES

<Fair and Healthy Competition with Competitors>

(1) No Restrictions on Free Business Practices

We must not engage in illegal agreements or arrangements that may lead to restrictions on free business practices as set forth by the applicable laws and regulations in this respect.

1. No Agreements with Competitors (No Cartels)
   We must not engage in price fixing or other illegal agreements or arrangements with competitors regarding sales volume, territories, customers or other competitive factors.
2. No Unethical or Unfair Bidding Arrangements
   We must not take part in any unethical or unfair bidding activity, such as fixing the successful bidder or contract price.
3. Prohibition on Certain Trade Association Activities
   When participating in trade associations or other meetings with companies in our industries, we must not participate in any way in actions or plans with competitors contemplated to form a cartel, rig bidding or interfere with companies newly entering a market or exclude other companies from a market. If presented with proposals by other companies to engage in these activities, to avoid any doubt, we must register our clear objections.

(2) No Unfair Trade Practices

We must not misappropriate the trade secrets of others and not engage in unfair trade practices such as untrue or misleading statements to customers about products of others.