GMO Internet Group
Compliance Declaration

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).

Commitment to stakeholders

A. For customers, business partners etc.

1. Appropriate advertising
   We will not make misleading displays, advertisements, or promotions to our customers.
2. Duty of explanation
   We will explain negative or risky information appropriately when explaining our products and services so that customers will understand with clear information and explanations.
3. Principle of conformity
   We will recommend the most suitable product based on a comprehensive assessment of the knowledge, experience, and the circumstances of customers.
4. Separation from anti-social forces
   We shall take a firm stand against anti-social forces and have no relationship with them.
5. Fair selection of suppliers
   In selecting suppliers, we will eliminate inappropriate provision or receipts of benefits and ensure transparency. In addition, we understand that transactions with companies owned by friends or relatives may constitute conflicts of interest, and we will consult with the departments in charge of legal and risk compliance if we are unsure of the decision.
6. Fair and equal business relationship
   We do not engage in discussions or agreements with business partners regarding sales terms and conditions that impede free competition. Also, we do not use our advantageous trading position to impose unfavorable trading conditions on our business partners or restrict them from doing business with third parties.
7. Gifts and entertainment policy
   In principle, we will decline gifts or entertainment from customers or suppliers and will not provide excessive or inappropriate gifts and entertainment beyond the bounds of social convention.
8. Fair competition
   We will not engage in any acts that impede fair and sound competition, such as obstructing business transactions with competitors or imposing unfair terms and conditions. Also, we do not use illegal or unethical means, such as hacking or bribery, to gather information about competitors, and in the case of information provided by third parties, we will confirm that the information has not been obtained in violation of laws, regulations, or contracts to the best of our ability.
9. Respect for intellectual property rights
   We respect the intellectual property rights of third parties and do not use or reproduce the works or trademarks of others without permission.

B. For shareholders, investors, and society

1. Accurate information disclosure
   We will appropriately disclose corporate information to shareholders, investors, and other stakeholders in an equal and timely manner.
2. Good relations with the local community
   In order to contribute to the realization of a prosperous society, we will actively support local communities through sports, culture, education, welfare, and environmental conservation activities.
3. Appropriate relationship with government
   We understand that there are regulations governing the relationships with public officials etc., and we will not engage in any conduct that could be suspected of bribery. If we are in doubt or have questions about whether it is regarded as bribery or not, we will consult with the legal or risk compliance departments.

Commitment to sound business practices

A. Accurate recording and reporting

1. Accurate business records and reports
   We understand that accurate business records are a source of trust for the company and ourselves, and we will accurately and properly record and report on expenses, hours worked, results of system development reviews, etc.
2. Accurate transaction records and reports (1)
   We make sure to keep record of any transaction, and store documents related to orders or deliveries and the related invoices for an appropriate period of time, as we understand their importance, and recognize these records serve as a prevention of problems with counterparties and the basis of tax treatment.
3. Accurate transaction records and reports (2)
   We recognize that the forgery or falsification of vouchers or data, or manipulation of the timing of recording revenues and expenses are serious fraudulent acts or even crimes and will never commit such acts.
4. Accurate accounting and internal controls
   We will perform accounting procedures faithfully and accurately in accordance with the appropriate laws, regulations, and standards. We will also establish appropriate workflows, including credit management, to ensure that all the information necessary for accounting is definitely collected, recorded, and managed.
5. Regulatory reporting
   We strive to ensure that all reports to regulatory authorities are prepared accurately, completely understandably, and on time.

B. Management of company property

1. Management of company property
   We will not use company property for non-business purposes or for personal gain and will manage such property with due care and respect. Company property includes the company's cash and deposits, products, equipment, and suppliers, as well as company trademarks and information learned in the course of duties.
2. Management of work hours
   We will not engage in personal activities during work hours that interfere with the performance of our duties. We will also not engage in activities that may cause discomfort to others, such as inappropriate personal gambling or pornography, or perform outside work on company computers or other equipment during work hours.

C. Information Management

1. Compliance with insider trading regulations
   We understand that stock trading using undisclosed material corporate information is a crime classified as insider trading and we will not engage in insider trading or transactions that may raise such suspicions.
2. Duty of confidentiality
   We will strictly manage confidential information, including personal information of customers, applicants, business partners and the company, and will not disclose such information to any third party without the consent of the customer or other parties or without legitimate reasons under the law. We will also manage confidential information appropriately so that it is not damaged, disclosed or leaked not only during our employment but also after resignation or termination.
3. Awareness of daily information management
   Recognizing that information leaks can occur through carelessness, we always check the e-mail addresses, including the CC and BCC fields, and ensure if the attached documents are appropriate. In addition, we do not open links or download files from emails that we do not recognize or that are suspicious.
4. Classification, use and storage of information
   We classify all information assets as confidential, confidential to the parties concerned, internal use only, or as open to the public in accordance with laws, regulations, and internal rules. We use all such information safely, and store it for a set period.
5. Use of electronic communication services and social media
   When sending or posting emails, SMS or social media (including but not limited to Facebook, LinkedIn, X, blogs, etc.) outside of work, we will not send or post content that includes confidential information or is detrimental to our customers, business partners or partners.

A promise to the partners we work with

1. Compliance with labor-related laws and regulations
   We will comply with labor-related laws and regulations and maintain awareness of the physical and mental well-being of all partners to the best of our ability.
2. Elimination of discrimination and harassment
   We do not tolerate prejudice or harassment on the grounds of race, national origin, gender, educational background, age, religion, sexual orientation, gender identity or any other personal characteristics. We will maintain a safe and ethical workplace.
3. Privacy protection
   We respect each other's privacy and will not unnecessarily pry into personal secrets, interfere with private lives, or inadvertently share another's private information with others.
4. Maintenance of open work environment
   We recognize that it is the mission of managers to create a work environment in which all partners can discuss discomfort and concerns without hesitation, and we will act accordingly.
5. Whistleblowing system
   When we see or hear of any fraudulent or illegal activities, we will consult with our direct managers or report to designated whistleblowing contacts. We will be grateful to those who have the courage to report such activities, and will never take any detrimental treatment against those who do so.
6. Lessons learned.
   GMO Incident Zero Day is designed as a day not to let past incidents fade away into obscurity, and we learn from the past every year. We apply the lessons learned to our current work, striving to achieve the goal of being No.1 in the industry.