Compliance with Laws and Regulations, etc. and Ethical Conduct

• We understand and will sincerely comply with applicable laws and regulations, both in Japan and overseas, and internal rules. We also fully recognize the expectations placed on us by society and we will fulfill these expectations by always practicing highly ethical conduct.
• Should we suspect that a violation of laws, regulations, or internal rules has occurred or should any other compliance concern arise in the course of our business activities, we will not overlook or conceal it, and swiftly make a report to a supervisor or the person responsible for legal affairs and compliance at the relevant Sansan Group company.

Protection of Information Assets and Personal Information

• We recognize that customer information and other information assets we deal with in the course of our business to be of the utmost importance as part of the Sansan Group’s management foundation and we will protect these information assets in accordance with the Information Security Policy.
• We will have the utmost respect for the privacy of individuals and we will handle all personal information appropriately based on the Privacy Policy (Personal Information Protection Policy).

Respect for Human Rights and Working Environments

• We will respect the human rights of all stakeholders connected to our business activities and ensure that working environments are fair, safe, healthy, and free from discrimination by acting in accordance with the Basic Policy on Human Rights.

Commitment to Fair Business Practices

1. (1) Fair Trade and Compliance with Competition Laws

   • We will comply with all applicable competition and anti-monopoly laws and conduct business activities based on fair and open competition.
   • We will not apply any unreasonable trading restrictions or use unfair trading methods that could impede fair competition.
   • We will not obtain trade secrets from other companies through unlawful methods. Furthermore, we will not use trade secrets from other companies while knowing that the information was obtained or may have been obtained through unlawful methods.

2. (2) Building Appropriate Relationships with Customers and Business Partners

   • We will always maintain fair and equal business relationships with customers and business partners and refrain from forcing unreasonable transaction conditions onto them. Furthermore, we will handle requests from customers and business partners sincerely.
   • We will select business partners based on fair and objective standards and work to build mutually beneficial relationships.

3. (3) Preventing Bribery and Corruption

   • In our relationships with public servants and officers and employees of other businesses, regardless of whether in Japan or overseas, we will act in accordance with the Basic Policy Regarding Prevention of Bribery and Corruption to prevent any form of bribery and corruption carried out with the aim of obtaining improper gain or business advantage.

4. (4) Preventing and Avoiding Conflicts of Interest

   • We will not engage in any actions that utilize the Company’s standing or authority to benefit ourselves or a third party at the expense of the Sansan Group’s interests, including transactions with Group companies, acting in competition with the Group, accepting kickback payments, or making personnel recommendations.
   • We will take reasonable care to ensure no conflicts of interest arise within our daily work activities and in the case that a conflict of interest becomes possible, we will swiftly report it to the Company and take appropriate measures, including making every possible effort to avoid such a situation.

Appropriate Use and Management of Company Assets

1. (1) Appropriate Use and Management of Company Assets

   • We will use company assets, both tangible and intangible, only after receiving proper authority and only for business purposes, and we will handle, manage, and store these assets appropriately to prevent damage or theft.
   • We will not make improper use of company assets or funds for personal reasons.

2. (2) Protecting and Respecting Intellectual Property Rights

   • We recognize that intellectual property rights are important assets within the Sansan Group’s business activities, and we will strive to protect and utilize them appropriately. We will also respect the intellectual property rights of third parties and take care not to use them illicitly or damage them.

Relationships with Society

1. (1) Social Contribution and Environmental Conservation

   • We will act in harmony with society and contribute to the realization of a sustainable society as a good corporate citizen.
   • We will consider the social and environmental impact of our business activities and actively engage in social contribution and environmental conservation through our business. Furthermore, we will encourage officers and employees to take interest in these activities and to actively take part and support their implementation.

2. (2) Prohibition of Relationships with Antisocial Forces

   • We strictly prohibit any kind of relationship with antisocial or unlawful forces that threaten the order and safety of society, and unreasonable demands from such organizations are handled based on the Basic Policy Regarding Antisocial Forces. We also ensure that we have no involvement whatsoever with criminal activity, including money laundering and the funding of terrorism.

3. (3) Political Donations and Contributions

   • We maintain transparent and sound relationships with individuals and organizations specified as being engaged in political activity and do not provide these with any support or favorable treatment.
   • In cases where we provide political contributions or donations to various organizations, we do so by using appropriate methods and in compliance with applicable laws and regulations, and internal rules.

Relationships with Shareholders and Investors

1. (1) Accurate Records

   • We ensure that accounting records and financial reports associated with our business activities are kept accurately and completely with no falsifications, alterations, or inaccuracies.

2. (2) Timely and Appropriate Information Disclosure

   • We will work to ensure transparent management and maintain the trust of society by disclosing company information to society and the stock market in an accurate, fair, timely, and appropriate manner. Furthermore, we will engage in constructive communication with shareholders and investors to facilitate sustainable growth and the medium- to long-term enhancement of corporate value.

3. (3) Preventing Insider Trading

   • We will not buy or sell shares of Sansan Group companies or any other company for which we have knowledge of unpublished material facts (insider information). When buying or selling shares of Sansan, Inc., we will follow the necessary procedures stipulated in internal regulations.
   • We strictly manage insider information and take the utmost care to prevent insider trading by connected individuals, including family members, by ensuring it is only shared within the scope necessary for conducting business.

Implementation of Basic Policy and Handling of Violations

1. (1) Conducting Education and Training

   • We provide regular education and training to ensure that officers and employees fully understand and can implement this basic policy. We also carry out ongoing awareness raising activities to improve awareness and provide knowledge concerning compliance.

2. (2) Establishment of an Internal Reporting System

   • We have established and are operating an internal reporting system with the aim of quickly detecting and correcting actions that are in violation of laws, regulations, or internal rules.
   • We protect the anonymity and confidentiality of whistleblowers and ensure that officers and employees who make a report are not subjected to any reprisals or disadvantageous treatment.

3. (3) Reports and Consultation Concerning Violations

   • In the case that we detect an act that violates laws, regulations, or internal rules, or an act that we suspect may be such a violation, we will report it to or consult with a supervisor or the internal reporting system at Sansan or a Sansan Group company.

4. (4) Corrective and Recurrence Prevention Measures in the Event of Violations

   • When an act is confirmed to have violated laws, regulations, or internal rules, disciplinary action will be taken against violators through swift and appropriate corrective measures. In addition, we will strive to build an even stronger compliance framework by formulating and implementing measures to identify the root cause and prevent recurrences.