GMO Internet Group
Compliance Declaration

(Precondition)

The basic philosophy for our compliance is as follows:

1. We will uphold the trust of our stakeholders and provide our customers with "smiles" and "enthusiasm" through high ethical standards and responsible behavior.
2. We will comply with relevant business laws to conduct appropriate business operations.
3. We will provide accurate service/product information.
4. We will carry out proper accounting.
5. We will carry out strict information management.
6. We will implement appropriate and timely information dissemination/disclosure.
7. We will eliminate insider trading.
8. We will eliminate discrimination and harassment as we strive to create a vibrant and safe workplace.
9. We will have no relationships with anti-social forces.
10. We will report fraudulent activity when we discover it.

(On society)

1. Compliance with relevant business laws
   We understand and strictly comply with relevant business laws and guidelines.
2. Compliance with insider trading regulations
   We understand that trading stocks by using unpublished and important company information is a crime known as insider trading, and we will not conduct insider trading or transactions that could cause similar doubts.
3. Respecting intellectual property rights
   We respect the intellectual property rights of third parties and will not use or duplicate copyrighted works or trademarks without the permission of the owner.
4. Separation from anti-social forces
   We have no relationships with anti-social forces and will respond to them firmly.
5. Announcement of information
   We strive for correct understanding and evaluation through the appropriate announcement of information.
6. Fair competition
   We respect the fair competition of the market and will not act to impede fair and honest competition through methods such as sabotaging our competitors' transactions or creating unreasonable terms and conditions.

(On our shareholders and investors)

1. Good communication with our shareholders and investors
   We will disclose company information fairly and promptly to our stakeholders, especially our shareholders and investors.
2. Accurate records
   We will accurately record all business information in accordance with laws, internal rules and regulations, and store them for a specified period of time.
3. Sincere and accurate accounting
   We will carry out accounting accurately and in good faith to comply with laws, regulations, and accounting standards, etc.
4. Focus on internal auditing
   We recognize that internal auditing is essential for sound corporate activities and will actively cooperate in internal auditing

(On customers and business partners)

1. Confidentiality
   We will strictly regulate confidential information of our customers, business partners, and companies, and will not disclose it to third parties without the customer's consent or legal reasons.
2. Principle of Suitability
   We will comprehensively judge the knowledge, experience, and request of the customer to recommend the most suitable product.
3. Duty of explanation
   We will explain even the negative or risky aspects of our products/services appropriately to prevent any misunderstandings.
4. Fair supplier selection
   We will ensure transparency when selecting suppliers.
5. Appropriate advertising
   We do not display/advertise/promote anything that would mislead customers.
6. Gifts and entertainment policy
   We will decline invitations and gifts from customers. In the event that we do accept, we will promptly report it to NASA using the entertainment reporting form.

(On management of company property/information)

1. Respect for company property
   We will properly manage our company's property and will not use its assets, such as supplies and consumables, privately.
2. Proper handling of information
   We recognize that confidential information of our customers, business partners, and companies, is an important asset, and will ensure that, even after we leave the company, the information is properly managed as to prevent damages or leaks.
3. Being conscious of daily information management
   We will conduct strict information management, keeping in mind that accidental leaks can happen.

(On healthy work environment)

1. Compliance with labor-related laws and regulations
   We will comply with labor-related laws and care about the physical and mental well-being of all partners.
2. Compliance with written rules
   We will carry out our duties according to the internal rules and regulations authorized by the company.
3. Appropriate reporting
   We will report accurately and appropriately on expenses, working hours, vacation days, etc.
4. Elimination of discrimination
   We do not tolerate prejudice on the grounds of race, nationality, gender, educational background, language, religion, and other personal characteristics.
5. Prohibition of harassment
   We will never engage in any violations of human rights, such as harassment.
6. Protection of Privacy
   All executives and partners will respect each other's privacy.
7. Maintenance of a fair environment
   It is the manager's responsibility to maintain a work environment that is fair and open to all.

(On the internal reporting system)

1. Reporting habits
   When any partner of the GMO Internet Group discovers or is requested something that is fraudulent or illegal, we will inform our direct manager or report to the designated contact point.
2. Attitude towards whistleblower
   We appreciate courageous whistleblowers but will never give any disadvantageous treatment.