In January 2002, Tokyu Corporation established "The Tokyu Group Compliance Guidelines" and began developing a framework for encouraging compliance across all departments of the Company and Tokyu Group companies. In April 2002, the Company adopted the "Tokyu Corporation Code of Conduct" (revised in May 2006), as the principles of action for all officers and employees.

The Tokyu Group Compliance Guidelines

As members of the Tokyu Group, we hereby establish our principles of action as follows, to embody and practice the Group ideals.

1. To establish the Tokyu brand with customer trust and support

(1) We will provide quality products and services with a commitment to customer comfort and confidence.
(2) We will give priority to communication with customers and provide information in good faith, and we will utilize the opinions of our customers to improve our operations.

2. To win fair valuations from investors

(3) Aiming at increasing corporate value on a sustained, long-term basis, we will operate our businesses in good faith.
(4) Taking investor confidence as a base, we will provide timely and appropriate information in good faith.

3. To engage in sound and fair market competition and aim at business growth

(5) We will conduct fair and transparent transactions and not follow unreasonable business practices.
(6) We will fully respect the property and rights of others, and conduct optimal procurement of management resources based on fairness and goodness.

4. To contribute to the progress of society based on recognition of business as a social existence

(7) We will actively address global environmental problems and seek to operate in a way that harmonizes with nature and the environment.
(8) As a good corporate citizen, we will seek to cooperate and coordinate with the community and continuously undertake social contribution activities.

5. To fulfill our responsibility as bearers of the Tokyu brand

(9) We will observe laws and regulations and internal discipline in every situation, act properly by following the dictates of social common sense and operate responsibly and in good faith.
(10) We have the strong recognition that intellectual property and information are important Company assets and will take every possible precaution in handling them.
(11) Based on the concept that the basis of corporate development is "people," we will respect each other's individuality and aim to create a working environment where people can make the most of their abilities.
(12) We will promote innovation by conducting regular and continuous self-auditing of operations and we will improve our business performance.


Tokyu Corporation Code of Conduct

April 1, 2002 Enforcement
May 1, 2006 Revision

1. To pursue the value that customers seek and develop and provide socially beneficial products and services while paying sufficient attention to safety and the protection of personal and client information

(1) Ensuring customer safety

We recognize that the safety of our customers is our primary concern at each stage of providing our products and services and we will take every measure in this respect.

(2) Appropriate response to customer opinions

We will respond promptly and sincerely to the opinions of our customers and use customer feedback to improve future business operations and services.

(3) Provision of customer-friendly products and services

We will emphasize marketing in designing products and services, properly understand the needs of customers and strive to provide safe, comfortable and adequate products and services.
We will provide fair presentations and conduct operating activities in good faith with due attention to customer opinions, to ensure that we provide information that enables customers to fully understand the content and characteristics of our products and services.

(4) Active use of information and protection of confidential information

We will make active use of information lawfully and properly acquired or prepared for the purposes of our business, properly manage the Company's fundamental information, customers' personal information and other confidential information, and will not divulge nor allow anyone to divulge any such information to anyone other than those with proper access to such information.
We will properly manage our information systems to make safe and efficient use of information as an important management resource, and strive to ensure its reliability and safety.

(5) Reliable and responsible performance of business operations

We will update the effective internal rules according to operating efficiency and the risks associated with our business and conduct our business in a responsible manner. We will constantly confirm the effectiveness of existing rules and improve them on an ongoing basis.

(6) Fair and transparent decision-making

We will not only make a sharp distinction between private and public matters in decision-making and operating judgment but make decisions in compliance with laws and regulations and internal rules and based on appropriate and accountable grounds.

(7) Protection of Company assets

We will treat our Company assets, a major source of corporate value, with extreme care and ensure that they are used properly.

(8) Protection of the Tokyu brand

We will commit to protecting the Tokyu brand, an important Company asset, in every situation.

2. To engage in fair, transparent and free competition and fair transactions and to maintain sound and normal relations with politicians and the government

(9) Strict compliance with the law

We understand not only the letter but also the spirit of laws and regulations and will not conduct any acts in violation.

(10) Fair and lawful business activities

We will not only comply with the Antimonopoly Act and other applicable laws and regulations but conduct fair and transparent business activities by eliminating inappropriate business practices.

(11) Prohibition of insider trading

We will never engage in insider trading, nor will we trade in shares or other instruments in a way that may invite suspicion.

(12) Optimal procurement activity

We will ensure fair, proper and lawful transactions with suppliers of goods and services and select suppliers based on compliance with laws and regulations, respect for human rights and environmental and other considerations.

(13) Prohibition of bribery and moderation of entertainment and gifts

We will never provide or accept gifts or entertainment that may lead to bribery or invite public suspicion or distrust.

(14) Respect for intellectual property

We will protect the Company's intellectual property rights and take particular care not to violate the rights of others.

3. To communicate not only with shareholders and investors but with the broader community and disclose corporate information in a positive and fair manner

(15) Fair, timely and appropriate information disclosure

To enable a proper understanding of the Company, we will disclose and transmit information to all stakeholders in a fair, timely and appropriate manner.

(16) Appropriate accounting procedures and reporting

In connection with our duties, we understand and will adhere to accounting standards and to accounting laws and regulations and will fulfill our responsibility with correct reporting.

4. To respect human rights in business activities as well as the diversity, individuality and personality of employees, provide safe, superior working environments and realize comfort and affluence

(17) Respect for human rights

We will operate based on a respect for fundamental human rights and strive to build a sound working environment without prejudice or harassment.

(18) Ensuring safe and healthy work environments

We will observe labor laws and regulations and internal regulations, build safe and healthy work environments and strive to maintain vibrant workplaces with good communications.

5. To recognize that environmental issues are a shared concern for all humanity and that addressing them is an essential requirement for corporate existence and activities and to act voluntarily and proactively

(19) Harmonization with the environment

We will observe laws and regulations and internal rules relating to the environment, conduct corporate activities in a way that reduces pressure on the environment, while as individuals also taking global environmental issues seriously and making our own best contribution to alleviating them.

6. To actively contribute to our communities as a good corporate citizen

(20) Coexistence with the community as a good corporate citizen

We recognize that progress for society, especially local communities, will strengthen the foundations that support the Company, and so we will strive to build a better society as a good corporate citizen.

7. To be resolute in the face of antisocial forces and groups that threaten the order and safety of civil society

(21) Rejection of relations with antisocial forces

We strongly reject relations with antisocial forces, and will build an organization that can be resolute against any trouble that may arise.