Compliance System and Compliance Program (Compliance Requirements)
1. What is Compliance?
Compliance refers to adherence to laws and regulations, and is also referred to as corporate ethics. In conducting business activities, stakeholders such as shareholders, business partners, consumers, and employees exist. Meeting the interests and demands of stakeholders requires the company's continued existence as a prerequisite. If profits are not generated through sound business practices, the company's long-term survival cannot be assured. Therefore, to pursue profits as part of business activities, it is necessary to comply with laws and regulations, the articles of incorporation, and various internal rules (including non-formal internal rules; hereinafter simply referred to as “various rules”) that function as corporate self-governance laws, while also maintaining ethical standards. This is compliance.
2. Compliance is practiced by each and every one of us
Corporate compliance is practiced when every board member and employee within the company thoroughly understands the meaning of compliance and acts in accordance with it in their daily business (work).
3. Compliance Consultation and Reporting Contacts
(1)Consultation and Reporting Contacts
Compliance-related reports and consultations to the Company shall, in principle, be made through the chain of command. However, if the chain of command is not functioning for any reasons, the 《General Manager of Administration》 shall serve as the Company's compliance consultation contact.
(2)Consultation and Reporting Rules
Compliance-related reports and consultations should generally be made through the chain of command. However, if the chain of command is not functioning for any reason, the 《General Manager of Administration》 serves as the Company's compliance consultation contact.
(1)Consultations and reports must be made under one's real name. The Company guarantees that no disadvantageous treatment will be given to the individual solely for having consulted or reported. Furthermore, any individual who believes they have suffered disadvantageous treatment solely because they consulted or reported may consult with the General Manager of Administration.
(2)The contact point shall provide feedback to the consultant or reporter regarding the handling of the matter consulted or reported.
(3)Investigation and response when issues arise shall be appropriately delegated to the responsible department based on the nature of the problem.
4. Response to Violations
If you discover any act or state of affairs violating this Compliance Program (Compliance Matters), receive instructions from a superior to engage in such a violation, or inadvertently violate it yourself, please consult with and report to your line supervisor (excluding the superior who gave the instructions, if applicable). If the reporting chain is inoperable for any reason, consult with or report directly to the designated consultation/reporting contact above. Note that while no specific penalties are stipulated for violations of this Compliance Program, decisions will be made based on the Employment Rules and other regulations according to the nature and circumstances of the case.
5. Compliance Program (Compliance Items)
The Company's Compliance Program (Compliance Items) consists of the following 14 items. This Compliance Program must be observed not only by the Company's officers and employees (including seconded employees), but also by individuals stationed or assigned to the Company under dispatch contracts, business consignment contracts, etc. Please note that this Compliance Program does not cover all compliance items; compliance with laws, regulations, and other rules not specified herein is also required.
Compliance Program (14 Items)
1.Respect for Human Rights; Prohibition of Discrimination and Sexual Harassment
2.Compliance with the Antimonopoly Act and Related Laws
We will not engage in private monopolies, unfair trade restrictions (cartels), or unfair trade practices.
3.Prohibition of Unfair Competition
We will not engage in unfair competition practices, such as manufacturing or selling counterfeit goods, or improperly obtaining or using trade secrets.
4.Compliance with Industry-Specific Laws
When conducting business activities, we must obtain necessary licenses and permits and comply with all applicable industry-specific laws.
5.Compliance with Insider Trading Regulations
We will not engage in any activities violating insider trading regulations.
6.Implementation of Appropriate Import/Export Procedures and Security Trade Management
We shall comply with all trade-related laws, regulations, and international treaties, and implement appropriate import/export procedures. Furthermore, to maintain international peace and security, we shall conduct strict trade management. We shall not only prevent legal violations but also refrain from handling goods that could be used or diverted for the proliferation of weapons of mass destruction, or engaging in any other inappropriate transactions.
7.Compliance with Intellectual Property Laws
Do not infringe upon intellectual property rights held by others.
8.Prohibition of Bribery and Gifts/Entertainment
Do not offer, promise, or provide bribes or improper benefits to foreign public officials. Furthermore, gifts or entertainment provided to business partners shall not exceed socially acceptable norms.
9.Prohibition of Providing Benefits to Antisocial Forces
We shall take a resolute stance against antisocial activities and forces, severing all relations with them.
10.Environmental Conservation
We shall be conscious of our responsibility as a good corporate citizen, striving to preserve a sound global environment while seeking harmony with the prosperity of human society.
11. Proper Management of Information
We must exercise the utmost care in managing our company's confidential information. Confidential information disclosed by third parties shall be treated with the same level of care.
12. Appropriate Use of Information Systems
We shall not misuse or harm our company's information systems.
13. Prohibition of Conflicts of Interest and Similar Acts
We shall perform our duties for the company with integrity and refrain from any actions contrary to the company's interests.
14. Implementation of Fair and Appropriate Accounting Practices
April,1 2026
Hideharu Kamakura
President & CEO