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. The Company also established the "Compliance Declaration," to observe laws, regulations, and social ethics, and establish a compliance structure. GMO's Board of Directors oversees the effectiveness of the "Spirit Venture Declaration" and "Compliance Declaration," and periodically reviews them as necessary.

• 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 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

GMO Internet Group has established various helplines to respond properly to stakeholders' feedback, questions, and concerns.

• 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. Retaliation against partners who have reported violations of laws and regulations to the company is prohibited if the reason behind it is whistleblowing.

• 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.

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. The Group believes this will further enhance the stakeholders' confidence in the organization and has established the "Compliance Declaration," which is a summary of the foundational beliefs. In order to promote and implement this Declaration, we provide training programs on the "Compliance Declaration" every year for all of our partners.
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 corruption prevention, at least once 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

As a business group that carries out business activities overseas, GMO Internet Group recognizes bribery risks, has established the "Guidelines to Prevent Bribery" as shared guidelines of the Group, and has a system to discover or prevent bribery at an early stage. Moreover, the company is aware that bribery and corruption prevention is a key issue, and the Board of Directors supervises the policies and guidelines.
In addition, we periodically evaluate the risk of corruption in each business area and are providing necessary education in business areas where the risk is high. GMO group is also encouraging the individuals to use the "GMO Helpline," a shared internal reporting system of the Group, or to promptly consult with the Group Legal Department if they have received requests that may be suspected to be the offering of bribes, such as goods or the payment of money to the targets for bribery established in each country. It also requires reports that are based on the forms to share the information about the gifts and entertainment from our customers.
Regarding corruption such as money laundering and insider trading, we also have a system to discover issues through the "GMO Helpline," a shared internal reporting system of the Group.
Furthermore, regarding business relations with new customers, GMO Internet Group will look up the attribute data on an external database as necessary and add an article defining compliance with bribery and corruption prevention to the contract.

The status of compliance violations

There were no relevant cases in FY2019, FY2020, and FY2021.