Basic Policy on the Prevention of Bribery and Other Corrupt Practices

The RACCOON Group hereby establishes the following basic policy on the prevention of bribery to ensure the integrity and transparency of our operations.

(Basic Policy)

The RACCOON Group adopts the following basic principles to prevent acts of bribery involving public officials and build fair and highly transparent relationships with business partners free from corruption. Officers and employees shall comply with the following provisions.

(Prevention of Bribery)

We will comply with anti-bribery laws and regulations, including the Unfair Competition Prevention Act and the Penal Code, both in Japan and overseas. Under no circumstances will we offer, solicit, pay, or receive bribes to or from any third party, including public officials or private business partners, for the purpose of obtaining benefits for the company or individuals.

(Prohibition of Facilitation Payments)

We will not make small payments (so-called “facilitation payments) intended to expedite administrative services that are not grounded in applicable laws or regulations.

(Ensuring Appropriate Provision and Receipt of Hospitality)

Any gifts or entertainment given to or received from business partners will be kept within the bounds of social courtesy.

(Record and Retention)

We will prepare and retain accurate accounting books and records for all transactions with reasonable detail.

(Internal Reporting System)

We have established internal reporting channels for consultation and reporting on any actual or suspected violations of compliance, including measures for bribery and corruption prevention. Two reporting and consultation channels are available: the company’s internal Compliance Office and an external law firm to which the Audit and Supervisory Committee members are affiliated. The Company strictly protects the confidentiality of whistleblowers and those seeking consultation, and ensures that they will not be subject to any disadvantageous treatment.

(Ensuring Full Awareness and Prevention)

We will provide education and training to officers and employees as necessary to enhance awareness and understanding of this policy, and thereby endeavor to prevent bribery and other corrupt practices.