1. Scope of application

This policy applies to all officers and employees (including non-regular employees, part-time employees, temporary employees, and fixed-term employees; hereafter, “Officers and Employees, etc.”) of the Daiseki Group. We will also encourage all of our business partners to understand this policy and strive to prevent corruption.

2. Organizational structure for preventing corruption

We will inform Officers and Employees, etc. of this policy and establish a necessary corruption prevention structure. To prevent corruption, we will operate the Compliance Committee in a fair and just manner based on this policy. When made aware of a suspected violation of this policy, we will immediately investigate the evidence and take appropriate measures.

3. Prohibited acts

We prohibit all forms of corrupt practices, including bribery^*, transactions involving a conflict of interest, misappropriation, coerced benefit sharing, bid-rigging, money laundering, insider trading, and unreasonable political contributions.

* Including payment of a disproportionate amount of fee for a service which has been provided and facilitation payment (payment of a small amount of money, with no legal grounds, to a public official to receive benefits)

4. Education

To maintain and reinforce the structure for preventing corruption, we will provide training to Officers and Employees, etc. when they join the company and regularly thereafter.

5. Appropriate accounting records and management

In accordance with our internal control system, we will keep accurate accounting records, etc. and ensure the proper storage of relevant business forms.

6. Monitoring

With regard to initiatives to prevent corruption and assess compliance, we will conduct self-inspections and internal audits to check if the structure for preventing corruption is functioning appropriately and improve the structure as necessary.

7. Establishment of a whistleblowing hotline

We will operate a consultation hotline, which enables Officers and Employees, etc. to report or seek advice immediately when they have recognized an act that violates or is suspected to violate laws or regulations related to the prevention of corruption or this policy. Use of the consultation hotline is kept strictly confidential, and users will not receive any disadvantageous treatment on the grounds of whistleblowing.

8. Action for dealing with violations, etc.

When we recognize corruption by a business partner, we will discontinue trading with that company. We will severely and promptly punish Officers and Employees, etc. who have violated laws or regulations related to the prevention of corruption or this policy.

May 9, 2025
Approved by the Board of Directors of Daiseki