Guidelines for Prevention of Insider Trading

Ajinomoto Group
Established on : April 1, 2020

  1. We fully recognize that it is highly probable that it will be illegal as an insider trading activity under applicable laws and regulations of each country, if, with knowledge of non-public important information on our company or other listed companies (regardless of whether or not the company belongs to the Ajinomoto Group; the same shall apply hereafter), we conduct the sale, purchase or other transactions of shares or other securities issued by such company before such information is made public, and if we recommend such sale, purchase or transactions to others.

  2. If we cannot confirm that the sale, purchase and other transactions as stated in the preceding paragraph and the recommendation of such sale, purchase and transactions to others are not illegal activities as insider trading under applicable laws and regulations of each country, we will not engage in such activities.

  3. In order to conduct the sale, purchase, or other transactions of shares or other securities issued by listed Ajinomoto Group companies, we will obtain a prior approval from the head of the compliance department of our company unless otherwise stipulated. If such person is unable to determine whether or not to approve, such person will contact Legal & Compliance Dept., Ajinomoto Co., Inc.

  4. In order to prevent insider trading, we will conduct adequate information management, including not to disclose non-public important information on our company or other companies to others unless it is necessary for the performance of duties.

  5. Each listed Ajinomoto Group company will take necessary measurements to prevent insider trading such as the establishment of internal rules in compliance with applicable laws and regulations of their respective countries that set forth procedures for officers and employees to conduct the sale, purchase or other transactions of the company’s shares and other securities. In addition, each listed Ajinomoto Group company will ensure that all officers and employees are aware of the significance and contents of insider trading regulations under applicable laws and regulations of their respective countries.



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