Code of Conduct

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A. General Provisions

1. Purpose

Leeden National Oxygen Ltd (the “company”) is committed to conducting its business with the highest level of integrity and ethics. This Code of Conduct (the “Code”) sets forth the basic guidelines for the conduct and concepts to be observed by all employees working in Leeden NOX Group of Companies (the “group companies”), enabling them to act in accordance with relevant laws and corporate ethics. This Code is established from the viewpoint of corporate social responsibility based on our belief that a relationship of mutual trust with customers or communities will be built through the continuous efforts in our day-to-day operations.

2. Scope of Application
  1. This Code will apply to any and all directors, officers and employees of the group companies, including temporary and part time staff.
  2. For the purpose of this Code, “the group companies” means collectively our company and all of the affiliate companies within and outside Singapore.
  3. Any amendment or abolition of this Code will only be made by the board of directors of our company.
3. Compliance with Code, etc
  1. We will adhere to this Code as well as laws and regulations together with internal codes in every aspect of our business activities. In the event that any problem actually arises or any potential problem is found in connection with our business activities, we will endeavor to resolve or prevent such problem on our own initiative.
  2. Each officer in a management position, including operating officers and directors, will comply with the Code and direct, supervise and cause any and all employees under supervision to comply with the Code.
  3. Any person who commits any act in violation of the Code or leaves such an act unaddressed may be subject to disciplinary action in accordance with the working regulations of our company, if such act falls under any breach of such working regulations.
4. Reporting Violations of the Code
  1. Any person who has discovered an act that violates or may violate the Code must promptly report such act.
  2. Employees are strongly encouraged to utilize our company’s open door policy to report any concerns or complaints by reporting to the Compliance Officer via email to
  3. No person reporting such a violation will receive any unfavorable treatment by reason of such report. We will ensure that any and all parts of such report, discussion or personal information of such person will be kept in strict confidence.
5. Establishment of Compliance Committee

We will establish a Compliance Committee that will discuss full compliance with the Code as well as significant policies related to it. The head of the Compliance Committee will be the Chief Compliance Officer (CCO) from Taiyo Nippon Sanso Holdings Singapore Pte Ltd.

B. Relationship with Society

1. Compliance with business laws

We will comply with the business laws applicable to our products and services, and ensure that we strictly follow the procedures for obtaining approval and licenses, and notifying the authorities according to the relevant business laws.

2. Control over political or other contributions

We will strictly refrain from offering bribes, profit sharing and illegal political donations and also from performing actions which may be misinterpreted as forming collusive relationships with politicians and governments, and we will endeavor to build sound and transparent relations with them.

3. Disassociation from antisocial elements

We will respond with fortitude to and have no relationships whatsoever with antisocial elements. If we receive an unreasonable demand from antisocial elements and the like, we will cope with it in a resolute manner, and will never seek to resolve such demands by offering money or any form of compensation.

4. Global environmental preservation and protection

For realization of global environmental protection and sustainable development we will endeavor to enhance our environmental awareness and to coexist with the environment in all aspects of our business activities through such efforts as energy saving, waste reduction, recycling promotion and appropriate management of chemical substances.

5. Export security control

For maintenance of security systems both domestically and internationally, we will strictly comply with all regulations under relevant laws and the internally designated procedures, confirm thoroughly the profile and description of our business partners in every export transaction, and ensure that no export goods/technologies will be used for any development, manufacture, or other activities relating to weapons of mass destruction of any kind.

6. Contribution to local and international community

In conducting business activities, we will respect the histories, cultures, religions, social norms and customs of the respective countries and communities and endeavor to establish a relationship of mutual trust with local communities. Furthermore, we will contribute to the development of the local and international community to create awareness of our responsibilities as a good corporate citizen.

C. Relationship with Customers, Business Partners and Competitors

1. Product safety
  1. We will always be mindful of safety in manufacturing, development, import, storage, sales, transportation, export, maintenance and repair of products. We will ensure that we fully understand and adhere to laws and standards concerning product safety, and we will consistently aim to achieve a higher level of safety.
  2. Whenever we obtain product safety-related information, we will promptly investigate the factual relevance of such information, and if any issue is identified, we will notify the relevant departments and sections and take appropriate action.
2. Quality control
  1. We will provide our customers only with those products which have been thoroughly examined in regard to quality and satisfy all requirements and quality standards under relevant laws and regulations. Furthermore, we will adhere to internal codes relevant to quality control.
  2. We will provide sufficient information including terms of use and environmental conditions which our customers need to know for safe use and handling of our products.
  3. In the event any problem arises in connection with the quality of our products, we will investigate the cause immediately and take appropriate actions to prevent recurrence of or remedy such problem.
3. Compliance with the antimonopoly law

Under no circumstances we will commit an act which violates or is seen to possibly violate the
antimonopoly law such as involvement in cartels, bid collusion and resale price maintenance, and we will conduct fair and free inter-enterprise competition.

4. Entertainment and gifts
  1. We will act in accordance with sound business practices and social norms in connection with any
    entertainment with or gift-giving to/from our business partners.
  2. In no circumstances will we offer bribes to any local government officials, or staff of government or local public bodies, nor will we offer them any improper business arrangement, business entertainment or gifts.
  3. Furthermore, we will neither commit an act that may be considered as bribery nor give favorable treatment to any public officers or staff of any foreign government for the purpose of receiving an improper business benefit.
5. Compliance with purchasing ethics, relevant laws and regulations

We will conduct our business with common decency and good faith with respect to our suppliers and carry it out fairly and equitably in accordance with the contracts with them and relevant laws and regulations. When conducting purchasing, we will not abuse our position as the purchaser and request unfair price discounts, services, largesse, and the like. Moreover, we will observe all commonly accepted social norms in connection with all entertainment or gift-giving to suppliers. In addition, we will select suppliers on the basis of rational criteria such as price, quality, and delivery schedules.

6. Control of personal information

We recognize the importance of protecting personal information, and therefore we will properly obtain, provide, or use personal information under our control in compliance with laws, regulations and internal codes. In addition, we will make further efforts to prevent and remedy any leak, loss, or damage of such personal information we hold by taking necessary and appropriate security measures.

7. Protection of intellectual property rights

We recognize that the intellectual property rights of a company including patents, utility models, designs, trademarks and copyrights are its business assets. Accordingly, we will ensure proper use and protection of such rights and respect the intellectual property rights of others.

D. Relationship with Shareholders and Investors

1. Disclosure of management information

We will disclose accurate management information such as the composition of finances and status of business activities of the group to our shareholders and investors. We will also convey to them the company’s management principles and policies in a clear manner, and be truly open to their views and criticism concerning these principles and policies.

2. Prohibition of Insider Transactions

When we obtain inside information on any of our group companies or on our business partners in the course of business activities, we will not buy or sell stock of the company in question until such information is made public. Moreover, that information will not be communicated or purchase recommendations made to enable another person to profit or avoid making a loss. We will ensure compliance with relevant laws and internal codes in relation to trading of stocks of our company.

E. Relationship with Employees

1. Respect of human rights

We will support and respect the internationally proclaimed human rights, and will not be complicit in human rights abuses.

2. Prohibition of discrimination

We will not engage in any discriminatory treatment in employment or other working conditions by reason of the nationality, race, sex, religion, creed, personal preference or social status of employees.

3. Prohibition of child labor and forced labor

We will support and implement effective elimination of child labor and abolition of forced labor in any form in accordance with internationally recognized rules.

4. Harassment

We will not allow any sexual harassment as well as any act which may be construed as sexual harassment or any other conduct which may impair the dignity of other employees in the workplace.

5. Protection of privacy

We will ensure that any personal information capable of identifying an individual or private information that may be known to us in the course of business activities will be kept under strict control to prevent leaks.

6. Workplace safety and health

We will understand and comply with the laws, regulations and the like concerning job-related safety and health. In the event of a work-related accident, we will give priority to ensuring workplace safety and endeavor to minimize the accident’s effects, and will ensure that the prescribed measures such as an immediate reporting are taken in order to prevent a recurrence of such accident.

7. Realization of better working environment

We will comply with labor relations acts and respect for the basic labor rights of employees. We will also encourage personal ability development as well as harmonization of work and life of employees and endeavor to build a better working environment that will provide them with the motivation to work and lead a satisfying life.

F. Relationship with the Company and the Company Assets

1. Compliance with employment regulations

We will always comply with the employment regulations.

2. Appropriate accounting treatment

We will accurately perform accounting processing in accordance with the relevant laws and regulations and the company rules. We will not make any false or fictitious entry, or hold unrecorded assets for the purpose of manipulating profit and loss or the like.

3. Prohibition of Transactions Involving Conflict of Interest

We will not be involved in any activities which are or threaten to be a conflict of interest with the company.

4. Management of sales secrets

We will properly keep corporate secrets in accordance with laws and regulations together with internal codes, and will not disclose or divulge such information without complying with the rules set forth by the company. We will not use such information for the purpose other than approved by the company. We will obtain corporate secrets only from persons authorized to disclose such information, and keep and use such information in an appropriate manner in accordance with laws and regulations together with internal codes.

5. Appropriate use of company assets

We will not use company assets and expenses for personal purposes.

6. Appropriate use of information system

We will use the company information system solely for business purposes, and not for personal reasons. We will place strict controls on IDs and passwords concerning the company information system and prevent leaks.

Furthermore, we will not attempt any unauthorized access of any computer systems under the control of other companies.


This Code covers a wide range of business practices and procedures. Although it may not cover every issue that may arise, it sets our basic principles to guide all employees of the group companies. Any employee who ignores or violates this Code, and any manager who penalizes a subordinate for trying to follow this Code, will be subject to corrective action, which may include immediate dismissal. However, it is not the threat of discipline that should govern your actions. We hope you share our belief that a dedicated commitment to ethical behavior is the right thing to do, is good business, and is the surest way for Leeden NOX to remain a highly successful company.

The company will review the Code on a regular basis and introduce revisions where necessary.

New version adapted from TNSC’s Code of Conduct implemented on 1 September 2017.