Corporate Ethics and Compliance

Promotion system and mechanism

Board of Directors

The Board of Directors not only formally confirms compliance, but also conducts monitoring to confirm the effectiveness of compliance.

Compliance Committee

In order to ensure thorough compliance, the Company has established the Compliance Committee chaired by the Representative Director in a bid to promote and manage a variety of necessary activities such as training. The Company has also established an internal reporting system for internal consultation and reporting on legal violations and other compliance issues.

Establishment of a whistleblowing contact point and protection of whistleblowers

The Company has set forth procedures for internal reporting in the Compliance and Risk Management Rules, and established a whistleblowing contact point. The General Manager of the Administrative Department or an outside lawyer is designated as the whistleblowing contact point, and the person in charge of handling whistleblowing promptly decides, upon receipt of a whistleblowing report, whether or not an investigation is necessary for the event reported and how to deal with the report.

Prevention of insider trading

Having established rules to prevent insider trading in the Rules for Prevention of Insider Trading, the Company strives to make the rules known throughout the Company, and plans to implement the following measures.

Hold regular inhouse training sessions to prevent insider trading

Establish a prior approval system for trading of the Company’s shares by officers and employees

Set a stock trading period for officers and employees and establish a system for ex-post reporting of the details of trading transactions

In addition, the Company checks the number of shares held and share transfers made by officers, employees, and their family members based on the list of shareholders at the end of the fiscal year and at the end of the interim period.

Elimination of antisocial forces

In order to ensure the appropriateness of the Company’s business operations, the Board of Directors has established the Basic Policy for Internal Control Systems, and one of the policies set forth in it is the System to Eliminate Antisocial Forces. The Policy states, “The Company shall reject any relationship with antisocial forces or groups that threaten the order and safety of civil society, and take a firm stand against any unreasonable demands from such forces in cooperation with lawyers,the police, etc.”Furthermore, as a system to eliminate antisocial forces, the Company has established Rules for Dealing with Antisocial Forces, Antisocial Forces Check Manual, and Manual for Dealing with Antisocial Forces, which are administered by the Administrative Department.