Basic Policy for Establishing the Internal Control System(Framework to Ensure Proper Business Conduct)
1. Framework to Ensure the Execution of Directors' and Employees'
Duties in Compliance with Laws and Articles of Incorporation
1-1.

The management structure consists of the Board of Directors,
Corporate Auditor, and Accounting Auditor.

1-2.

Regular meetings of the Board of Directors are held to establish asufficient framework for directors to monitor the legality andcompliance with articles of incorporation in the execution of theirduties.

1-3.

Officers and employees share the corporate philosophy and "Corporate
Code of Ethics," ensuring thorough compliance by making it a standard
for all business operations.

1-4.

For risk management and compliance, we establish the " Corporate
Code of Ethics" and the "Risk & Compliance Regulations," set up a Risk& Compliance Committee chaired by the President and establish adepartment with a secretariat function under its jurisdiction. We
conduct comprehensive management and establish risk & compliancemanagers in each department or region for detailed management at
each business location.

1-5.

Directors and Corporate Auditors shall immediately report significant
facts related to violations of laws and internal regulations to the Boardof Directors.

1-6.

By utilizing the internal reporting system, we detect illegal andinappropriate acts early on and take appropriate and necessary
measures.

1-7.

We strengthen the structure through the use of the "Legal
Management

System,"monitoring

amendments

tolaws,andimplementing internal audits.
2. Framework for the Preservation and Management of Information
related to the Execution of Directors' Duties
2-1. Information related to the execution of duties is preserved andmanaged in accordance with the "Document Management andRetention Regulations," using documents or electronic records toensure access by Directors.
2-2. Electronic records will be managed based on the "Information SecurityRegulations."
3. Regulations and Other Frameworks for the Management of Loss andRisk
3-1.

Crisis Management: In the event of risks or crisis, we take prompt
initial measures based on the "Crisis Management Regulations" tominimize damage and prevent recurrence.

3-2. Emergency Measures: For significant incidents or disasters affecting
business significantly are addressed organizationally based on the"Emergency Measures Regulations."
3-3. Business Continuity Management (BCM): Identifying risks of businessinterruption, assessing their impact on business activities, developinga Business Continuity Plan (BCP) and establishing a BCM framework.
Additionally, conducting simulations.
3-4. Credit Management: Conducting proper credit management based onthe "Credit and Receivables Management Regulations" to prevent theoccurrence of bad debts.
4. Framework to Ensure the Efficient Execution of Directors' Duties
4-1. The Board of Directors formulates and executes management plans
for the company and group companies. Monthly meetings are held todecide on management strategies and supervise the progress ofbusiness operations. Furthermore, to expedite decision-making andstreamline business operations based on the basic policies decided bythe Board of Directors, Executive meetings are held twice a month.
4-2. Corporate Auditors conduct audits to evaluate the effectiveness ofinternal control.
5. Framework to Ensure Proper Business Conduct in the Corporate Groupconsisting of The Company and Subsidiaries
5-1. Reporting structure for matters related to the execution of duties byDirectors of subsidiaries to the Company.
Directors in each group companies supervise the execution of business,and regularly report to the Board of Directors and ExecutiveCommittee of the company.
5-2. Regulations and other frameworks for the management of loss andrisk in subsidiaries. The company comprehensively manages
compliance, information preservation and management, and risk
management for group companies. We request reports as needed andprovide necessary advice and guidance.
5-3. Framework to ensure the efficient execution of duties by Directors andemployees of subsidiaries. When group companies make crucial
decisions, the company request the submission of relevant documents
in advance, and if necessary, provide guidance or advice.
5-4. Framework to ensure that the execution of duties by Directors andEmployees of subsidiaries complies with laws and articles ofincorporation. The company's corporate philosophy and " Corporate
Code of Ethics" are shared and adhered to by group companies,ensuring thorough compliance. Additionally, the audit department
conducts regular audits of group companies.
6. Matters related to the personnel appointed when Auditors request
assistance in performing their duties.
Personnel of the audit department assist Auditors in their duties as directed.
7. Matters related to the independence of the personnel mentioned in thepreceding clause from the Directors
Personnel changes and disciplinary measures for the above mentioned
assistants require prior consent from the Corporate Auditors. The CorporateAuditors may express opinions on the personnel evaluation of theseassistants.
8. Framework for reporting to Corporate Auditors by Directors andEmployees, and other reporting systems to the Corporate Auditors
8-1.

Framework for Directors and Employees to report to the Corporate
Auditors
Directors and Employees provide necessary reports in response to theCorporate Auditor's requests. Corporate Auditor, attend Board
meetings and other important meetings, review relevant documentsand request explanations from Directors or Employees as needed.

Furthermore, the Corporate Auditor will receive explanations from thecompany's accounting auditor regarding the content of the audit andengage in information exchange.
8-2.

Framework for reporting by Directors, Corporate Auditors, employees
executing duties in group companies, or those who have received
reports from them to the Corporate Auditor. Crucial events in groupcompanies are obligated to be reported to the company, and theCorporate Auditor are informed of the reported content.

9. Framework to ensure that those who have reported do not receiveunfavorable treatment
The "Corporate Code of Ethics," shared by the company and groupcompanies,

stipulates

thatinternal

whistleblowers

will

not

face

disadvantages due to their reports.
10.Policy on handling costs or liabilities arising from the execution of theCorporate Auditor's duties
Measures are taken to ensure the effectiveness of audits while managing thecosts arising from the execution of the Corporate Auditor's duties.
11.Other frameworks to ensure the effective execution of the Corporate
Auditor's audits
Directors pay attention to the establishment of a framework to ensure thatthe Corporate Auditor can perform its duties appropriately and engage in
information and opinion exchange with the Corporate Auditor.
Revision History
Established: May 24, 2006
Revised: August 1, 2021
Revised: October 16, 2023