ACOM Group Code of Ethics and Code of Conduct

ACOM Group Code of Ethics

Enacted December 1, 2007
Amended April 1, 2020

"We, the ACOM Group, in recognition of our corporate social responsibilities and mission, and in light of our commitment to the Circle of Trust that embodies the spirit of our founders, pledge to maintain standards of conduct in accordance with the Corporate Philosophy predicated on that spirit under the ACOM Group Code of Ethics as follows.

1. We shall choose the correct course of action at all times in line with the fundamental principle of demonstrating respect for others.
2. We shall strive to improve ourselves every day, based on a full understanding of laws and regulations relevant to our work and a commitment to full compliance with same.
3. We shall adhere to the Putting the Customer First policy, respond to our customers' needs and strive to deliver the highest standards of service.
4. We shall respect the confidentiality of customer details and other information obtained in the course of our work.
5. We shall ensure that corporate information is released in a timely and suitable manner for the purpose of promoting corporate transparency.
6. As responsible members of society, we shall contribute to incarnation of sustainable society through our business activities and community programs and activities.
7. We shall strive to prevent financial crimes such as money laundering and terrorist financing while we stand firmly against the actions of any anti-social forces or groups posing a threat to public order or safety.

Code of Conduct

Enacted December 1, 2007
Amended April 1, 2020
Amended June 1, 2026

The Code of Conduct sets out expected standards for ACOM representatives in line with the ACOM Group Code of Ethics.

1. Respect for Others

   1. Basis of Conduct

      We will make it a fundamental principle of our conduct to respect the dignity, privacy, and fundamental human rights of our customers and all individuals. We will at all times strive to act in a manner befitting officers and employees of ACOM and the ACOM Group.

   2. Fair and Equitable Treatment

      We will respect each officer and employee's right to fair and equitable treatment and will not engage in discriminatory conduct on the basis of race, nationality, place of origin, beliefs, religion, gender, sexual orientation, gender identity, gender expression, age, disability, health condition, or any other such grounds.

   3. Workplace Environment

      1. ①We will respect diverse values and work together to create a safe and healthy workplace where each officer and employee can fully realise their abilities. By understanding and supporting diverse working styles, we will foster a workplace where everyone can work effectively.
      2. ②We will respect one another as partners in our work and treat each other with sincerity and consideration. In doing so, we will create a workplace where open and constructive communication takes place with due regard for physical and mental health and safety.
      3. ③We will not engage in any form of harassment, including sexual harassment and power harassment, that undermines individual dignity or has a serious impact on organisational operations.

2. Compliance with Laws and Regulations

   1. Compliance with Laws and Regulations

      1. ①We recognise that the Company's continued existence depends on strict compliance with laws and regulations and on acting with fairness and integrity based on high ethical standards. In our business activities, we will take care not to pursue profitability alone.
      2. ②In carrying out our duties, we will ensure that we fully understand the laws and regulations on which they are based, as well as the intent and purpose of those laws and regulations, and act in accordance with a correct interpretation.

   2. Fairness in Corporate Activities

      1. ①We recognise and respect the importance of fair and free competition and will act in accordance with fair market rules and proper business practices in all our business activities.
      2. ②We will ensure that any entertainment or gift-giving, whether offered or received, does not become excessive in value, scale or frequency and remains within the bounds of socially accepted business courtesies, and will conduct such activities appropriately so as not to give rise to suspicion or distrust.

   3. Conflict of Interest

      We will not engage in any conduct that creates a conflict of interest between an individual and the company, customers or other parties. Should any conflict of interest arise, we will resolve it appropriately in accordance with applicable laws, regulations, and internal rules.

   4. Asset Management

      We will recognise our responsibility to properly protect and manage the tangible and intangible assets associated with our business operations and will handle them appropriately at all times without using them for personal purposes or causing damage.

   5. Reporting, Consultation and Notification of Issues

      1. ①We will promptly report or consult with a supervisor, or report to the internal whistleblowing system, if we discover any conduct that violates or may violate laws or internal rules.
      2. ②We will handle any reports, consultations and whistleblowing with strict confidentiality, ensure that no disadvantage arises to those who report or raise concerns, and respond appropriately if any issues are identified.

3. Customer First

   1. Basic Approach

      We will always act with a customer-first mindset and with fairness and integrity, taking due care to ensure that customers' interests are not unfairly harmed.

   2. Provision of Products and Services

      1. ①We will strive to understand the increasingly diverse needs of our customers and provide products and services that enhance their quality of life.
      2. ②We will strive to acquire professional knowledge and skills to create products and services that exceed customer expectations.

   3. Information about Products and Services

      We will use accurate and clear language when explaining our products and services and ensure that contracts are entered into only after customers have fully understood the terms and conditions.

   4. Handling of Complaints and Related Matters

      We will respond promptly and appropriately to customer enquiries, consultations and complaints, share relevant information with appropriate departments to improve and develop our products and services, and, where inappropriate conduct is identified, take corrective action and work to prevent recurrence.

4. Information Management and Confidentiality Obligations

   1. Approach to Handling Information

      We recognise our responsibility to properly manage personal information, business partner information, and information relating to corporate management, and will exercise the utmost care to prevent unauthorised access, loss, alteration and or unauthorised disclosure.

   2. Confidentiality Obligations

      We will strictly safeguard personal information, business partner information and confidential information relating to company management obtained in the course of our duties and will not disclose such information to any third party without a legitimate reason or consent, both during and after our employment.

   3. Inside Information

      We will not use material non-public information obtained in the course of our duties that may affect share prices to trade in shares or other securities, or to otherwise seek to benefit ourselves or others.

5. Disclosure of Corporate Information

   1. Reporting of Disclosed Information

      We will report information related to our business activities, financial matters, and other relevant areas accurately and appropriately so that shareholders, investors, and customers can make rational decisions.

   2. Accounting Practices

      We will maintain appropriate accounts based on accurate records to ensure the reliability of our financial accounts.

6. Social Contribution

   1. Giving Back to Communities

      We will respect the history, cultures and customs of communities both in Japan and abroad and contribute to their sustainable development through our business activities and active participation in social contribution activities. We will also support initiatives that promote culture, education and sports, and cooperate in efforts to provide appropriate assistance through social welfare organisations.

   2. Environmental Programs

      We will recognise the importance of environmental conservation and work to conserve resources and energy. We will also take steps to reduce waste and promote the use of recycled materials.

   3. Volunteering

      We will strive to engage in voluntary activities that contribute to society.

7. Approach to Financial Crime, Including Anti-social Forces

   1. Anti-Social Forces

      We will have no dealings whatsoever with antisocial forces and, in the event of any improper demands or acts of business interference, will promptly report such matters to the relevant authorities and seek their assistance as appropriate.

   2. Countermeasures against Money Laundering and Terrorist Financing

      We will work to prevent all forms of financial crime associated with the products and services we provide. In particular, we will rigorously implement measures to prevent money laundering and terrorist financing and eliminate such activities.

   3. Prohibition of Bribery

      We will not engage in bribery or any other conduct involving the offering or acceptance of money or benefits for the purpose of obtaining improper advantage. We will also not falsify or conceal business records to hide such conduct.

Basic Principles in Relation to Anti-social Forces

Enacted July 1, 2009

All employees of the ACOM Group are committed to upholding our basic policy on anti-social forces as detailed below in order to maintain the integrity and security of our business operations.