Establishment of corporate code of conduct accompanying the adoption of a holding company structure

As part of establishing an internal control system, we are establishing a code of conduct so that all employees internalize Kokusai Kogyo Holding Group's basic sense of values and ethics and reflect them in their business conduct.

1. Establishment of corporate code of conduct for the Group
In establishing Kokusai Kogyo Holdings Corporate Code of Conduct, we are beginning with the existing Kokusai Kogyo Group Corporate Code of Conduct, which consists of the Kokusai Kogyo Group Corporate Ideology and Charter of Conduct, and adding the necessary revisions, such as changes in the company name as well as the names of divisions and departments.

2. Creation of a compliance manual
We are creating the Kokusai Kogyo Holdings Compliance Manual by adding necessary revisions to the existing Kokusai Kogyo Group Compliance Manual.

June 24, 2009

Sandra Wu, Wen-Hsiu
President