Compliance

GMO Internet Group Compliance Declaration

GMO Internet Group believes that all of its executives and employees (we call "partners" hereafter) should act with integrity in accordance with laws and, regulations, and adhere to social norms based on the "Venture Spirit Declaration" our corporate philosophy, which outlines our consistent goals and values, and which allows us to earn the trust of stakeholders. This Compliance Declaration provides guidelines to ensure that we, as partners, act correctly and appropriately, maintain trust in our company, and continue to a corporate group that will last for 100 years. We put this guidance into practice, protect our services, customers, and partners, create "smiles" and "excitement" for everyone involved, and strive to be a group that continues to grow.

Basic Philosophy

1. We recognize that each of us represents the company. We act with high ethical standards and aim to earn the trust of all stakeholders.
2. We will abide by GMO Internet Group's Venture Spirit Declaration and this Compliance Declaration, and we will not pursue profits in violation of either.
3. We will comply with all applicable laws, regulations, and company rules and standards of conduct. Our actions will demonstrate a transparent and honest approach that is not detrimental to our customers, society, or to our own families.
4. We respect human rights, which are the birthright of all people, recognize diverse values, and create a working environment where every partner's motivations and abilities can be fully demonstrated.
5. When we find any acts or suspicious activity, contrary to or in breach of laws, regulations, social norms, or our Compliance Declaration, or when we face a situation that requires us to act in a manner that is contrary to them, we will not turn a blind eye but will consult with our superiors or the appropriate departments. If we are unable to consult with our superiors or the appropriate department, we will report through the internal reporting system (GMO helpline).

Framework

The Group shares the mindset it has cultivated in the form of the "Spirit Venture Declaration," and sets it as the foundation of its corporate activities. In addition, we have established a code of conduct for ethical and compliance-based actions required of our partners, named the "Compliance Declaration," and have established a compliance structure. The Management Council oversees the penetration and effectiveness of the "Spirit Venture Declaration" and the "Compliance Declaration," and periodically revises and approves them.

• At the meetings of the Board of Directors and the Management Council, where management decisions are made and execution of duties is reported, legality is confirmed by seeking the opinions of the Audit and Supervisory Committee Members with respect to all agendas.
• The Company also holds "Compliance Workshops," establishes the "GMO Helpline" to operate a consultation and whistleblowing framework, and works to ensure the effectiveness of prevention, early detection, and self-correction of fraudulent acts, etc. in an effort to enhance compliance management.
• The "Group Financial Business Cooperation & Group Internal Audit Office" conducts audits to determine whether the execution of business is in compliance with laws, regulations, the Articles of Incorporation, etc.
• Furthermore, the Company has established the "Risk Management Committee." A meeting of the Committee is convened in principle on a monthly basis, to discover at an early stage compliance risk information that may cause damage to the Group and respond to risks that become evident.
• In addition, the Company also holds quarterly "Group Compliance Meetings" that the legal officers at the Group's public listed companies participate in and regularly shares the situation of a compliance system of other companies in the Group to achieve the enhancement of the compliance throughout the Group. Furthermore, the Group's information is reported immediately to Group Legal Department as soon as compliance violations occur, and we have established a system that responds appropriately and quickly.

Internal reporting system

We have established internal reporting channels for our partners and external reporting channels for other individuals, with the external reporting channels being available to anyone outside of the company, including former employees. Reports are independently investigated by the relevant department, which then provides feedback to the whistleblower regarding the investigation and response outcomes. In addition, when illegal acts are found, they are promptly corrected, and the offender is punished and the reporter is rewarded in accordance with the employment regulations.

• GMO Helpline/Nadeshiko Helpline

  In order to discover, ameliorate, or prevent all compliance risks, including overall bribery and corruption prevention in business activities, and human rights infringements at an early stage, we have a system that enables partners to consult with the company or solve problems, without undue worry, if they become aware of fraudulent acts or illegal acts in work, or if they see or hear acts that may be illegal though it's uncertain whether the acts are clearly illegal. We also have female consultants in case the female partners are unlikely to consult with male consultants (available for use by male partners as well). Whistleblowing can also be anonymous.
  Personal information, comments, or details of the consultation of individuals who consult with us will be managed under strict guard and we will never leak them to third parties without their acceptance. In addition, we prohibit retaliation against partners who report violations of laws and regulations to the Company because they have reported such violations, and we respond in good faith to ensure that those who have suffered human rights violations receive redress.

• External helpline to report problems

  If the actions of our directors, partners, etc. are a possible violation of laws and regulations, we have an external helpline to report (or facilitate consultation on) those problems. This helpline is available for use by anyone outside the company, which includes customers and retired workers. Whistleblowing can also be anonymous.
  https://www.gmo.jp/contact/compliance/[Japanese version only]

Education and training program

The Board and partners should comply with laws and regulations, be ethical, and be capable of taking actions based on our corporate philosophy of the Venture Spirit Declaration. We believe that compliance with social norms, ethics and common sense, and acting with integrity by all directors and partners will lead to the trust of our stakeholders, so we have established the "Compliance Declaration," a code of conduct based on social ethics and compliance that is expected of our group's partners. In order to promote and implement this Declaration, we provide training programs on the "Compliance Declaration" every year for all of our partners, and evaluate the effectiveness of the training through questionnaires.
We provide training programs on the introductory guide to compliance for new graduates and mid-career partners when they join the Company. We also provide training programs on compliance, including bribery and comprehensive corruption prevention, 4 times a year for all partners, and specific theme ranges from insider trading or harassment prevention to personal information protection and information security. GMO Internet Group is working hard to enhance compliance consciousness and reinforce knowledge.

Corruption prevention initiatives

The Group recognizes the importance of comprehensive anti-corruption measures (including the prevention of bribery, insider trading and money laundering), and the Board of Directors regularly oversees the status of anti-corruption measures.
In addition, we regularly assess the comprehensive corruption risk in each business, and provide necessary education in business areas with high risk. For example, in our business activities in Southeast Asia, we have a system in place to prevent corruption, such as requiring that all transactions be approved by a Japanese manager.

Furthermore, in the event that corruption such as bribery, insider trading, or money laundering is discovered, we have a system in place to ensure that it is reported promptly to the relevant officers, including the representative director, using a dedicated reporting form, in order to ensure that corruption is detected at an early stage.
In addition, we also require that entertainment and gifts from business partners be reported using a shared form.
Also, we have established a Group's common "Compliance Declaration" and "Anti-Bribery Guidelines" to raise awareness among our partners (employees). We encourage the use of the Group's common internal reporting system(GMO Helpline) for reporting misconduct, including corruption, and compliance violations, and have established a system that allows for the anonymous reporting of such issues, so that we can identify problems as widely as possible.
In our relationships with business partners, we will conduct appropriate due diligence to prevent corruption.
Specifically, we use external databases and AI to search for attribute information as necessary, and we include clauses in our contracts that prevent bribery, corruption, and the involvement of antisocial forces.
Additionally, with regard to involvement in politics and policy, we recognize the social responsibility of our group, which provides internet infrastructure services, and we will strive to appropriately engage in areas closely related to our business, based on the social significance of the policies involved, in order to contribute to the public interest.

• Status of partner disciplinary actions or dismissals for corruption prevention There were no applicable cases in FY2023.
• Status of fines, surcharges, and settlement payments for corruption prevention There were no applicable cases in FY2023.

The status of compliance violations

There were no applicable cases from FY2019 to FY2022.