Promax Automotive, Inc. Compliance Program Established July 2010

1. Promax Automotive, Inc. Compliance Program Established July 2010 Previously (since 2002) followed Itochu’s Policy

2. Promax Automotive, Inc. • Promax participates in the Itochu Group Compliance Program and complies with all terms and conditions of the Itochu program, which is made a part of the Promax program by reference hereto. • If you have any comments or questions about this document, please contact the ADM department of Promax. Telephone: 765-447-4340 or 513-603-6011. Email: abishop@promaxauto.com or csanders@promaxauto.com. • Promax Automotive has been in compliance with the Itochu Group Compliance Program since its inception in November, 2002. This document is a supplemental document to the Itochu program and is intended to supply the information specific to Promax only.

3. July, 2010To All Associates of Promax • The Itochu Group Compliance Program defines basic policies about compliance within the Itochu Group. Promax wishes to further the promotion of compliance activities in the future and has therefore completed this additional statement of Promax's Compliance Program to align the compliance activities and the contents of both Programs as much as possible. We intend to review the contents of the Programs annually with the goal of improving the necessary systems. • All associates of Promax are encouraged to review the compliance program and individual specific measures to encourage stricter compliance in each associate’s job responsibilities. • Recently the word “compliance” is used more frequently and more effective systems are being established. However, misconduct, incidents, or accidents in connection with compliance still occur and Promax is no exception. Compliance-related problems seriously affect business activities, and can bring a company to its knees. Therefore Promax must deal with compliance-related problems seriously. • We hope that all management members of Promax will carry out reviews of the compliance system and basic actions, stress timely reporting of incidents, encourage compliance training to help prevent occurrences, and act under the basic Itochu philosophies of “ Acts of fraud and violations can never be permitted” and “Obeying laws and regulations is a fundamental rule.” Y. Hayano CEO/President G. A. Bishop CAO and Compliance Officer Promax Automotive, Inc.

4. Table of Contents • Section Page Number • Definitions of Compliance-related Terms Used in the ITOCHU Group 5 • I. Purpose of Establishing the ITOCHU Group Compliance System 6 • II. System Outline 8 • 1. Chief Compliance Officer (CCO) 8 • 2. Compliance Committee 8 • 3. Compliance Meetings 8 • III. Preventive Measures 9 • 1. Compliance Education, Training, and Awareness Building 9 • 2. Law Lists 10 • 3. Law Manuals 11 • 4. Obtaining Written Confirmations from All Employees (Including Executives) of ITOCHU Corporation 11 • 5. Creating a Compliance Contact Network 12 IV. Appropriate Countermeasures 13 • 1. Countermeasures against Compliance Incidents 13 • 2. Hotline 17 • 3 .PROMAX Corporation Employee Performance Evaluations 17 V. Measures for Continuous Improvement 18 • 1. Formulation of Annual Compliance Policies 19 • 2. Monitor and Review System 19 • 3. Internal Audits 21 • 4. Periodic Reviews and Revisions of the Compliance Program 22

5. Definitions of Compliance-related Terms Used in the ITOCHU/Promax Group • Company-wide Law: A law or theme applicable to all companies, regardless of the industry, when doing business, etc. • Special Industrial Law: A law applicable to a certain industry (or certain products or services) when doing business. • Law List: A list of Company-wide Laws and Special Industry Laws relating to the business or products that an organization conducts or handles. It is used as a checklist when doing business or beginning a new business. • Law Manual: A detailed manual that is designed to help users comply with the laws contained in the Law List. It describes the laws and shows specific measures to take when an illegal act is discovered. • Compliance Incident: Any of the following events that occurs in ITOCHU Corporation or any ITOCHU Group Company (companies subject to compliance management): • An event that may violate any law, internal regulation, or other rules • An event that may fall under any of the cases subject to disciplinary action stipulated in ITOCHU Corporation’s Employment Regulations • An event that may exert an adverse effect on the human body or the natural environment • Compliance Contact Network: A list covering each stage of the route through which information about the occurrence or the possibility of occurrence of a Compliance Incident will be communicated from the workplace to the Compliance Officer of the organization, as well as respective contacts. • Consultation Desk: A help desk providing advice about all matters concerning compliance in general. • Hotline: A system with which any inside informant may directly provide a designated person or department (whether internal or external) with internal information about a Compliance Incident if such internal information was once reported through an ordinary reporting route but the Compliance Incident is not corrected or if it is difficult to report through an ordinary reporting route. • Monitor and Review System: A method of periodically verifying and checking the compliance performance of each organization through questionnaires, meetings, or other proper approaches so that all members of the organization, including the top management, may share the results and determine improvement measures. • Company subject to compliance management: Any Group Company for which the managing Division Company or Division deems compliance management to be necessary. • PDCA cycle: A continuous improvement cycle or activity in which “Plan (P), Do (D), Check (C), and A (Act)” are repeated.

6. Purpose of Establishing the Promax Group Compliance System 1. Basic Theory • Compliance is the fundamental concept underlying the social existence of an enterprise. A compliance system is a “System to Ensure Compliance by Directors and Employees with Laws, Regulations and the Articles of Incorporation.” • To achieve this basic policy, establish a system for improving the compliance of Promax. • To reinforce the compliance system, implement the system and measures shown below: • [Prevention] • Establishment and continuous improvement of a compliance system • Establish a system required to prevent violations of laws, etc. and continuously improve it through periodic reviews. • Continuous education in compliance • Provide continuous education and enlightenment concerning compliance to help each employee understand the intent of laws, etc. and observe them with the highest standards of ethics. • [Countermeasure] • Proper action against Compliance Incidents • When a Compliance Incident occurs, take proper action with the maintenance and protection of the corporate brand kept in mind, and try to achieve further improvement through the “investigation of the cause,” the “formulation and implementation of measures to prevent recurrence and follow-ups,”and “proper internal punishments.” 2. This “Promax Group Compliance Program” describes Promax’s system to reinforce the compliance of the ITOCHU Group/Promax. 3. Each organization sets its own “compliance program” reflecting the characteristics of the organization such as its scale, business category, line of products and services, and the region where it exists, based on the “ITOCHU Group Compliance Program.”

7. «Reference: Conceptual outline of compliance system» • Internal control • Observance of laws, etc. • Reinforcement of compliance • Promax Compliance Program • Establishment of a compliance system • Preventive measures • Proper countermeasures • Promax creates a compliance program taking into account its characteristics, establishes, maintains, and upgrades the system for reinforcing compliance, and repeats the PDCA cycle.

8. II. System Outline • Promax establishes the following organizations as a system to instill the basic theory described above. • 1. Compliance Officer (CO) • The Compliance Officer shall: 1) assist the President/CEO and establish, maintain, and control a compliance system from a company-wide standpoint; 2) preside over the Compliance Committee; 3) be authorized to give directions to General Managers of the Operational Departments to establish, maintain, and upgrade a compliance system, if necessary; and 4) execute duties according to special orders from the President/CEO. 5) Perform the duties stated in “Appendix 1: duties of Compliance Officers” in the Itochu Group Compliance program. 6) Act as a consultation desk on matters about compliance and provide consultations within the company and take necessary action. • 2. Compliance Committee • 1) Chair - Compliance Officer • 2) Vice Chairman - Human Resources Manager • 3) Committee members - As assigned by CEO, current committee is HR Manager, CAO and CEO. • 4) Position Advisory committee for President/CEO • 5) Roles: Deliberate and determine compliance-related basic policies Monitor and approve the status of integrated control of compliance Deliberate the establishment and maintenance of a compliance system Evaluate the implementation status of the compliance system and deliberate and determine an improvement plan (Deliberation only when otherwise specified in the Rules for Management Authority and Responsibility) Monitor the progress of improvement measures and provide guidance to the relevant internal departments • 3. Compliance Meetings • Annual meeting of the compliance committee shall be held to enable the Compliance Committee members to share information and cooperate with one another. • Annual meeting at III to be attended by Promax’s HR Manager

9. III. Preventive Measures • To make each employee more aware of compliance for the purpose of preventing Compliance Incidents, Promax must not only organize and continuously improve its “compliance system” but also instill all compliance-related matters (including items that must be observed) in all employees and conduct ongoing education and training. • 1. Compliance Education, Training, and Awareness Building • Promax considers education and training to be one of the most important issues in connection with strict compliance and plans and conducts various education and training programs, including education to rebuild or raise awareness in each employee and education to impart knowledge about observing specific rules (laws, internal rules, etc.) when performing operations. • (1) Promax company-wide training • The Compliance Officer, the Human Resources Department, and other relevant Administration Department personnel shall work together to conduct seminars and training sessions that consider the years of service and the roles of the employees, and assist each department in providing education for the employees under its control (described in 2) below. • (2) Training for employees under a department’s control • Promax shall plan and conduct compliance education and training for employees under its control under the initiative of the Compliance Officer. • When planning education and training, the “purpose (awareness rebuilding, knowledge training, prevention of occurrence/recurrence of incidents, understanding of systems, etc.),” “target personnel,” “methods,” “schedules,” and “specific contents” shall be discussed to improve effectiveness. • Messages delivered by the top management of Promax have quite an impact on instilling compliance and therefore, must be considered. • (3) Company-wide training • Promax shall conduct internal seminars concerning applicable laws and themes (including explanation of relevant internal regulations), circulate documents (timely dissemination of information about revisions and abolition of laws, the application of laws, etc.), prepare manuals, discuss specific approaches to compliance education and training and awareness building, and carry out necessary measures. The Compliance Committee shall lead these activities.

10. 2. Law Lists • A “Law List” shall be used as a means to “know” all applicable laws in doing business (Company-wide Laws and Special Industry Laws*) and must be updated and made known to all employees as much as possible. Law Lists shall be reviewed and revised at least semi-annually taking into account revisions and additions of laws, rules, industrial standards, etc. and changes of the line of products or business category. • *Company-wide Laws • Laws and themes applicable to all businesses, irrespective of the industry. • *Special Industry Laws • Laws applicable to doing business in a specific industry (line of products, services, etc.) The General Manager or higher level person in charge of each department shall be responsible for providing a list of the specific industry laws which are applicable to it’s operations to the Compliance Committee. • (1) ITOCHU Corporation’s Company-wide Laws • ITOCHU Corporation shall appoint one of the Headquarters Administration Divisions as a division responsible for Company-wide Laws. This division shall monitor revisions of laws and themes, dispatch information, establish a system for strict compliance, and conduct education and training and other necessary controls. • The above-mentioned division responsible for Company-wide Laws will assist Promax in preparing a “Company-wide Law List” when requested to do so. • (2) IAAI’s Law List • IAAI prepares a “Company-wide Law List” according to the laws of the United States to teach these laws to all employees. • IAAI shall study and list Special Industry Laws, relevant ministerial ordinances, and industrial standards relating to the products and services it handles based on the actual situation, and prepare a “Special Industry Law List” stating the “status of approval/registration,” the “appointment of qualified personnel,” “responsible organizations (personnel) and reporting routes,” and “items requiring special attention” to teach these laws to all employees (including Promax). • The prepared “Company-wide Law List” and “Special Industry Law List” shall be reviewed and revised periodically.

11. (3) Promax’s Law List • Promax shall prepare a “Company-wide Law List” to teach these laws to all employees. • Promax shall also study and list Special Industry Laws, relevant ordinances and industrial standards relating to the products and services it handles based on the actual situation, and prepare a “Special Industry Law List” stating the “status of approval/registration,” the “appointment of qualified personnel,” “responsible organizations (personnel) and reporting routes,” and “items requiring special attention” to teach these laws to all employees. • The prepared “Company-wide Law List” and “Special Industry Law List” shall be reviewed and revised semi-annually. • 3. Law Manuals Based on prepared “Law Lists,” compile “Law Manuals” according to the degree of necessity and importance, which explain applicable laws and describe specific actions to be taken when any violation is discovered, and disseminate them to all necessary employees for their training and education. Review and revise the manuals periodically (at least annually) taking into account revisions and additions of laws, rules, industrial standards, etc. as well as changes in the line of products or business category. 4. Obtaining Written Confirmations from All Employees (Including Executives) of Promax Automotive, Inc. In principle, obtain written confirmations annually from all executives and employees (including temporary staff and locally hired employees declaring that they shall “observe laws and internal rules”. Review these written confirmations at the end of the year. The Human Resources Department is responsible for obtaining written confirmations with the cooperation of relevant departments.

12. 6. Creating a Compliance Contact Network • To promptly provide relevant departments (and the top management as appropriate) with accurate information in case of a Compliance Incident, Promax shall create a “contact network” in advance according to the <reporting and action flows shown in IV-1> described later. • Worksite → Compliance Officer → Relevant department (and up to the top management as appropriate) • When creating and distributing a “contact network,” handle personal and other information about each person with extreme care, including his/her mobile phone number.

13. IV. Appropriate Countermeasures • In case of a Compliance Incident, it is necessary to conduct various measures, including promptly collecting and communicating information and giving proper instructions to the relevant parties. Measures, including the following, shall be formulated and continuously improved so that appropriate countermeasures can be carried out without fail in case of an emergency. • 1. Countermeasures against Compliance Incidents • All employees and persons responsible within Promax must report and communicate Compliance Incidents (*) promptly and accurately according to the reporting and action flows shown on the pages that follow. • In case of a Compliance Incident, submit a “report on the occurrence of the incident,” an “interim report” for proper action against it, and a “final report” containing the investigated cause, measures to prevent recurrence (formulation/implementation/follow-up, etc.), and proper internal punishment, through the reporting routes described in (1) to (3) in 1) Reporting below. • (*) Compliance Incidents - Any of the following events that occur in Promax: • An event that may violate any law, internal regulation, or other rules • An event that may fall under any of the cases subject to disciplinary action stipulated in PROMAX’s Employment Regulations • An event that may cause an adverse effect on the human body or the natural environment. • 1) Reporting (ordinary reporting route) • (1) Reporting by employees • All employees within Promax must immediately report the occurrence of a Compliance Incident or the possibility thereof to the person responsible in their organizations through their superiors whenever they notice it. All employees of Promax must also endeavor to report the occurrence of a Compliance Incident or the possibility thereof not only in their own department but also in other departments. • <See the reporting and action routes in case of Compliance Incidents shown on the pages that follow.>

14. (2) Reporting by responsible persons • The responsible person within Promax must report to the Compliance Officer when he/she has received a report on the occurrence of a Compliance Incident in the field that the person is responsible for or in other cases when a Compliance Incident has occurred or may occur. • <See the reporting and action routes in case of Compliance Incidents shown on the pages that follow.> • (3) Reporting based on internal regulations • As for Compliance Incidents that must be reported according to the separately defined internal regulations, etc. under the control of and implemented by Promax, all employees and the responsible person must report them through the appropriate reporting routes shown below and according to the concerned internal regulations, etc.. However, if another responsible internal person is appointed according to the concerned internal regulations, Compliance Incidents may be reported via the responsible person. • (4) Timing of reporting • (i) Reporting in case of a Compliance Incident • In case of a Compliance Incident, promptly report the fact discovered at the time of reporting through the appropriate reporting route (ordinary reporting route) shown in 1) above. • (ii) Interim report • Properly report the information collected and the facts detected after reporting the occurrence of the Compliance Incident, the progress of measures and policies, etc., if necessary, through the appropriate reporting route shown in 1) above. • (iii) Final report Upon completion of measures against the Compliance Incident, submit a final report that summarizes the incident. • 2) Measures against a Compliance Incident • If a Compliance Incident occurs, discuss, determine, and carry out the necessary measures. • (1) Get the facts • Get the facts by questioning the concerned personnel and investigating documents about the organization where the incident occurred, an overview of the incident, the persons) involved in it, when and how it was carried out, and how it was detected. • (2) Considering whether a response, a report, or an announcement to regulatory authorities, customers, and concerned external parties is necessary • After getting the facts behind the Compliance Incident, discuss whether a response, a report, or an announcement to regulatory authorities, customers, and concerned external parties is necessary, and take proper action. • Keep the following in mind when announcing a Compliance Incident to the public.

15. (i) Make official announcements through the CEO/President • If necessary the CEO shall appoint a person responsible for corporate communications. • (ii) Cooperation with ITOCHU Corporation • If a Compliance Incident occurs within Promax which the CEO reports to Itochu through IAAI, promptly cooperate with the Corporate Communications Division of ITOCHU Corporation to coordinate mass media communication if necessary. • (3) Collecting detailed information • Obtain detailed information that was not revealed at the time of the occurrence of the Compliance Incident (including background and motive for the incident, whether any internal system or check function exists, amount of loss (direct cost or cost incurred by correction)). • (4) Investigation of the cause • Based on the background and motive, etc. for the Compliance Incident, conduct employee interviews to look for flaws in the internal system or check function, and verify and investigate the cause. • (5) Formulation and implementation of measures to prevent recurrence and follow-up • Based on the result of the investigation of the cause, determine and implement direct or medium- and long-term measures to prevent the recurrence of the same incident or the occurrence of similar incidents. • Additionally, follow up on the progress of the formulated measures to prevent recurrence. • (6) Proper internal disciplinary punishment • With regard to each Compliance Incident, determine whether any internal disciplinary punishment is required according to the internal regulations (employment regulations, etc.) of Promax. If necessary, consult the President of Promax and other relevant divisions (such as Itochu International Inc.(III)) about what disciplinary punishment is appropriate before it is carried out. • <See Itochu Group Compliance Program Appendix 3: ITOCHU Corporation’s Employment Regulations (Excerpts of Regulations Concerning Internal Disciplinary Punishment)>

16. Reporting and action flows in case of a Compliance Incident within Promax • Employee reports to Superior • Superior reports to Person responsible, person in charge, etc based on Promax’s organization chart • Person in charge reports to General Manager of Department • General Manager reports to Compliance Committee • Compliance Committee reports to Compliance Officer • Compliance Officer reports to President • President provides instruction to Compliance Officer • Compliance Officer provides instruction on recurrence prevention to Compliance Committee • Compliance Committee provides instruction on recurrence prevention to General Manager. HR Manager includes incident on monthly report to Itochu International Inc. • General Manager provides instruction to Person in Charge. If incident warrants increased training or follow up training, a staff meeting is held to discuss all measures to be taken and training to be implemented. • OR • Open door policy allows reporting to skip steps listed above and report directly to someone else at a higher level. • OR • Hotline allows for anonymous reporting to independent company hired by Promax.

17. 2. Hotline • 1) A hotline is set up so that inside informants can provide designated external company directly with information if a Compliance Incident is not corrected although internal information about it was reported through the <ordinary reporting route shown in IV-1> or if it is difficult to report it through the ordinary reporting route. • 2). All employees of Promax can use its hotline system when providing internal information concerning the company or other employees of the company. • 3) Information on Hotline is posted on the Promax Intranet. • 3. PROMAX Automotive’s Employee Evaluations • When compliance violations arise, Promax will assess the performance and action of employees on the compliance-related matters. The system functions separately from the internal disciplinary punishment system. • Promax will also use the results of any human resource assessments as a guide for the development of and guidance for employees, including compliance awareness building in employees.

18. V. Measures for Continuous Improvement • After implementing the Compliance system established by Promax, it is important to review and improve it to keep it optimum for the current status or business situation of the organization. Promax shall also continuously improve and sophisticate the compliance system described in this Compliance Program by setting medium- and long-term policies and items on which priority should be placed for a specific period of time and periodically following the PDCA cycle (a continuous improvement cycle or activity in which “Plan (P) -Do (D)- Check (C)- Act (A)” will be repeated) as described below. PLAN • Formulate Annual Compliance Policies and programs for implementing compliance, and set targets ACT Formulation of improvement measures based on monitoring and reviews • Examination and implementation of strict punishments and measures to prevent recurrence DO • Carry out programs • Conduct education and awareness activities (including preparation of manuals) • Deal with individual Compliance Incidents (including response through the hotline) CHECK Monitor and review of the implementation status of programs Collection and reporting of accurate information Internal audits

19. 1. Formulation of Annual Compliance Policies • Promax shall define Annual Compliance Policies as specifically as possible based on the necessary laws and regulations for its business, line of products, transaction status, and business category as well as the matters required to observe them, and review them on a semi-annual basis to continuously improve them. • When formulating Annual Compliance Policies, various factors including the following shall be considered. Not only annual policies but also medium- and long-term policies shall be reviewed. • ● Results of monitoring and reviews and other internal surveys • ● Causes of Compliance Incidents that occurred, incident types, relevant laws, etc. • ● Existence of the Compliance Incident risks based on those that occurred in other organizations of the Group and other company’s cases • The Annual Compliance Policies shall cover the entire organization under control (including subsidiary companies when applicable), and the managing organization shall disseminate the policies and provide necessary assistance for implementing them. • The department responsible for “Company-wide Laws” shall monitor the compliance status within the group regarding the Company-wide Laws under control, identify the situation as well, and formulate policies as specifically as possible for further compliance. • 2. Monitor and Review System • Promax shall monitor and review the implementation status of compliance-related Annual Compliance Policies described in 1 above, the operating status of systems, the legal and other compliance status, and the progress of education, training, and awareness improvement in order to identify its current situation and issues. • 1) Promax monitoring and review: Semi-annual • Promax shall individually monitor and review the organization with an approach appropriate to the scale and staffing of the organization (written questionnaires, hearings, etc.). In the monitoring and review process, Promax shall conduct verification of survey items and collected answers to assess under the initiative of the Compliance Officer of the organization. The Compliance Office of IAAI, III or Itochu may perform a secondary review at each site if necessary. • *Reference for setting items • Survey matching the business characteristics (business category, line of products, country, culture, and custom) of Promax. • Response to revisions of Special Industry Laws and the extent of observance of laws • Survey of the establishment and implementation status of the compliance system • Formulation, review, and installation status of the “Compliance Program,” “Law Lists,” “Law Manuals,” etc. • Operating status of the compliance-related systems, including the hotline system • Status of subsidiary control, if applicable. • 2) Group-wide monitor and review by the Compliance Office, Legal Division of ITOCHU Corporation: Semi-annual • The Compliance Office, Legal Division shall simultaneously monitor and review the entire ITOCHU Group. • The Compliance Office, Legal Division shall report to the Compliance Committee of ITOCHU Corporation the results of the monitoring and review and what each organization must do based on the results. The report content approved by the Committee shall be fed back to each organization so it can improve its system in the future.

20. Compliance Committee at Itochu Compliance Office, Legal Division • <<Image of group-wide monitoring and review conducted by the Compliance Office, Legal Division>> Compliance Officer of Promax Promax Employees The Compliance office, Legal Division of Itochu sends the review questionnaire to Promax’s Compliance Officer, who in turn sends the review questionnaire to Promax Employees. When the Promax employees answer review questionnaire, it is returned to the Promax Compliance Officer and then to the Itochu Legal Division Compliance Office. The Compliance Office will then report the review results to the Itochu Compliance Committee. The Itochu Compliance Committee will then review and report questionnaire results and announce the Committee’s decisions and report content to the Legal Division Compliance Office and then to Promax’s Compliance Officer. Promax’s Compliance officer will review results with the Promax Compliance Committee and employees as necessary. Steps in Process: Send review questionnaire Answer to review Report review results Report questionnaire results and announce Committee’s decisions and report content

21. 3) Monitoring and reviewing Company-wide Laws • The Administration Department responsible for Company-wide Laws shall review the necessity of monitoring and reviews, at least annually, based on the compliance status of each Company-wide Law. If necessary, the method and timing of monitoring and reviews as well as target departments shall be determined and the monitoring and reviews shall be implemented accordingly. • 4) Result report and feedback • Each organization shall report the results of the monitoring and reviews described above and results of individual monitoring to its top management, and feed back the report content and instructions and decisions by the top management to all employees of each organization under its control so they can share the survey results within each organization. • If any matter that needs to be improved is discovered, it shall be promptly reported to the relevant departments to enable them to take proper actions, and advice shall be given to the department involved in the matter to take corrective actions. • 3. Internal Audits • Internal audits, which differ from the separately specified monitor and review system conducted by Compliance Officers, are effective in continuously improving compliance systems. • Promax may have two types of internal audits as described below to check the implementation status of the compliance system. • 1) Periodic audit • The Compliance Committee may perform an audit according to the audit schedule it sets to verify whether the compliance system of Promax is fully functioning. The audit shall include verification of the monitor and review system of the Compliance Officer and a check of matters such as whether the PDCA cycle is working. Advice and proposals for improvement shall be provided as appropriate. • 2) Ordinary audit • In an ordinary audit by Itochu Corporation or IAAI, the implementation status of the compliance system in Promax shall be checked, and advice and proposals for improvement shall be provided as appropriate. Itochu or IAAI may perform partial audits or audits of particular segments of Promax as they deem necessary.

22. 4. Periodic Reviews and Revisions of the Compliance Program • Promax’s Compliance Officer shall review, refine, and upgrade the contents of this Compliance Program annually, at a minimum. Refer to the Itochu Group Compliance Program for: Appendix 1: Chart of Compliance Officer Duties and Appendix 3: Employment Regulations of Itochu. Both Appendix 1 and Appendix 3 are applicable to Promax Automotive, Inc and are a part of Promax’s Compliance Program.