Group Ethics Policy

Ethics Philosophy

Bestex Kyoei Co., Ltd. and its affiliates (hereinafter "the Group") regard compliance as a fundamental pillar of our management. Moving beyond mere adherence to laws and regulations, we are dedicated to conducting sincere, fair, and equitable corporate activities that meet the expectations and demands of society.

Scope of Application

This Policy applies to all officers and employees of the Group, as well as to all business activities across our operations. Every individual is expected to thoroughly understand this Policy and act with a high standard of ethics and good judgment in their daily duties.

Implementation Framework

To ensure the effectiveness of this Policy, we establish an operational framework centered on the Risk Oversight Committee—chaired by the Risk Management Officer and vice-chaired by the Compliance Officer—under the supervision of the Executive Committee, which comprises members including the President and Representative Director as well as Directors. Operating through this Committee and the CSR/Corporate Governance Secretariat, we monitor compliance status across the entire Group and regularly report the results to the Executive Committee.

Basic Principles

1. Compliance with Laws and Regulations

The Group strictly complies with the laws, regulations, and internal rules of all countries and regions where we conduct business activities. We never engage in acts that deviate from societal norms, operating with high ethical standards and personal accountability.

2. Prohibition of Corrupt Practices

We prohibit all forms of corruption, including bribery, across all countries and regions where we operate. In accordance with internal regulations such as the "Regulations on Entertainment, Gifts, and Condolences," we do not offer or accept entertainment or gifts intended to secure unfair benefits or business advantages, maintaining healthy and transparent relationships. Furthermore, we strictly forbid all fraudulent and improper conduct, including false expense claims, data falsification, and embezzlement.

3. Prohibition of Conflicts of Interest

We prohibit actions that create, or may appear to create, a conflict between personal interests and the interests of the company. Officers and employees must not leverage their corporate positions or non-public information obtained through their duties for personal gain (including insider trading) and must always prioritize the company's best interests in compliance with relevant laws and internal rules.

4. Maintenance of Fair and Free Competition

We strictly avoid all unfair trade practices, including anti-competitive behaviors such as bid-rigging and cartels, as well as abuse of a superior bargaining position. We consistently operate our business under the principles of fair and free market competition.

5. Prevention of Money Laundering and Terrorist Financing

To ensure that our business activities, products, and services are not exploited for money laundering, terrorist financing, or funding the proliferation of weapons of mass destruction, we strictly comply with internal regulations and relevant laws, including security trade control, and address risks appropriately.

6. Elimination of Antisocial Forces

We maintain zero tolerance for and no involvement with antisocial forces or groups that threaten public order and safety, firmly rejecting any unreasonable or unlawful demands under all circumstances.

7. Responsible Information Management and Protection of Intellectual Property

Client information, personal data, and confidential information acquired during business operations are handled responsibly in accordance with our internal Information Security Regulations, Personal Information Protection Policy, and applicable laws. We enforce robust information security measures to prevent leaks and unauthorized use. Additionally, while protecting the Group's intellectual property rights, we respect the intellectual property rights of third parties and strictly refrain from infringement.

Whistleblowing System

To ensure the early detection and remediation of compliance violations or potential risks, the Group maintains and operates an internal whistleblowing system, with the Internal Audit Office serving as the primary point of contact. We strictly guarantee caller confidentiality and ensure that no individual will face adverse treatment or retaliation for submitting a report in good faith.

Comprehensive Education and Awareness

To cultivate and maintain a high standard of ethical awareness, we conduct regular education and training programs for all officers and employees. Furthermore, we ensure this Policy is thoroughly communicated across the organization and require all officers and employees to sign an acknowledgment and compliance agreement.

Disciplinary Action

Any officer or employee who violates this Policy or relevant laws and regulations shall be subject to strict disciplinary action in accordance with Employment Regulations. Additionally, if a violation results in financial or operational harm to the company, we reserve the right to seek damages, including taking necessary legal action.

Information Disclosure and Communication

In accordance with this Policy, we cultivate corporate ethics through transparent communication with our stakeholders. Furthermore, this Policy is made publicly available both internally and externally to maintain a high level of communication transparency.