The Pioneer Group Code of Conduct (this "Code") applies to all individuals working at the Pioneer group of companies (the "Pioneer Group"), including all executives and officers. This Code shall be periodically reviewed, and the approval of the Board of Directors of Pioneer Corporation shall be sought to make revisions when deemed necessary.

Each company in the Pioneer Group (the "company") shall translate this Code into the language appropriate for, and consistent with, the legal systems and social practices for the region and country in which it operates. This Code is to be distributed among and understood by all applicable individuals throughout the company. As part of the process of translation, explanations or provisions may be added with regard to the contents of this Code; provided, however, that such provisions do not conflict with or undermine the substance of this Code or other provisions of this Code. The Pioneer headquarters of each world region shall lead these efforts, based on the approval of the Board of Directors of Pioneer Corporation.

We will encourage contractors and suppliers serving on behalf of the company to meet our ethical standards and promote corporate social responsibility.

The Business Ethics Committee has been established at Pioneer Corporation to implement this Code throughout the Pioneer Group. The administrative office of the Committee has also been established at Pioneer Corporation to manage to the Business Ethics Hotline and to promote Business Ethics.