Basic Policy on the Development of Internal Controls Systems
Tokyo Gas Co., Ltd. (hereinafter “the Company”) is committed to achieving sustainable growth andincreasing corporate value over the medium to long term by clarifying management and execution
responsibilities, strengthening supervision and auditing functions, and promoting accurate and prompt
decision-making and efficient business execution, while ensuring legality, soundness, and transparency
based on its Management Philosophy.
The group of companies consisting of the Company and its subsidiaries (hereinafter collectively referredto as “the Group”) shall aim for its perpetual development by respecting each company’s independency
and setting the pursuit of overall optimization as its philosophy.
In light of the above, the Board of Directors shall establish a basic policy for the development of theinternal controls system in order to ensure the appropriateness of the Group's business operations. Basedon this Policy, the Corporate Executive Officers shall assume the role and responsibility of effectively
establishing and operating the internal controls system of the Group.
1. System to Ensure that the Execution of Duties by Officers and Employees of the Group
Complies with Laws and Regulations and the Articles of Incorporation(1) Establish and comply with the “Our Code of Conduct” as the basis of the compliance system.
(2) Establish the philosophy and system of the compliance activities and work for the growth ofcompliance awareness by continuous education and training, etc.
(3) Establish internal reporting and consultation service counters both within and outside the Group, andreport the status of their operation to the Audit Committee. No person who uses the aforementioned
service counters shall be subject to any disadvantageous treatment on the basis of having used theservice counters.
(4) Establish an organization to manage the rules and regulations related to the internal controls of theGroup to ensure legal compliance, cyber security, and similar matters.
(5) Establish a department in charge of the internal audit of the Group (hereinafter the “Internal Audit
Department”) to efficiently and effectively audit the status of business operations. The Internal Audit
Department shall report the results of its audits to the Audit Committee and the directors, etc., of theaudited subsidiaries.
(6) Establish policies and systems for the development and operation of internal controls over financial
reports and the evaluation of their effectiveness, and ensure the reliability of financial reporting.
(7) Establish policies and systems for the prevention of insider trading and information disclosure, andensure the legality, appropriateness, and promptness of the handling of relevant information.
(8) Set forth matters such as resolutely rejecting illegal or unreasonable demands from anti-social forces,etc., in “Our Code of Conduct,” and take appropriate measures.
2. System for Storage and Management of Information Related to the Execution of Duties by

Corporate Executive Officers(1) Set forth the handling of documents and electronic or magnetic records with respect to information,etc., related to the execution of duties by Corporate Executive Officers, and store and manage suchinformation in an appropriate and reliable manner, making it available for inspection as necessary.
3. Rules and Other Systems for Management of the Risk of Loss of the Group(1) Establish and operate the risk management system in accordance with the “Risk Management Policy”
with the Representative Corporate Executive Officer, President and CEO as the General Manager.
The system shall be structured to immediately report to the Corporate Executive Officers and AuditCommittee members when matters that may cause serious damage to management are found.
(2) Set forth a system and business continuity plan in the event of a disaster, manufacturing and supply
disruption, or other unexpected emergency, and take prompt and appropriate action.
4. Systems to Ensure Efficient Execution of Duties by Corporate Executive Officers(1) Regularly report to the Board of Directors on the formulation and progress of the medium- and longterm management plans and single-year management plans of the Company and its important
subsidiaries, as well as other matters prescribed in the “Regulations of the Board of Directors.”(2) Establish a meeting body to support the rational decision-making of Corporate Executive Officers on
important management matters, and consider multiple aspects as necessary. Establish an advisory
body to the said meeting body to make recommendations from a professional perspective on mattersrelated to investment, capital contribution, financing, and other important matters.
(3) Set forth the decision-making authority and division of duties regarding the execution of business
operations, and clarify the responsibilities and authority thereof.
5. System to Ensure Appropriateness of Operations at the Group's Subsidiaries(1) Set forth policies and systems for the management of subsidiaries, require the directors, etc., ofsubsidiaries to determine the basic policies for the development of internal controls systems andestablish and operate such systems, and manage subsidiaries through the approval of matters to besubmitted to the shareholders meetings of subsidiaries and the reporting of other important matters,etc.
6. Matters Concerning Employees, etc., Assisting the Audit Committee in Performing its Duties(1) Establish a dedicated organization to assist the Audit Committee in its duties and assign necessary
employees, etc. Prepare an environment in which such employees, etc., can smoothly perform suchsupporting duties under the direction and orders of the Audit Committee.
(2) Decisions on personnel-related matters concerning such employees, etc., shall be made with theconsent of the Audit Committee.

7. System for Reporting to the Audit Committee and System for Ensuring Effective Auditing bythe Audit Committee(1) The officers, employees, etc., of the Group shall report to the Audit Committee or the Audit Committee
members without delay on matters prescribed by laws and regulations, or on matters for which theAudit Committee requests a report. No person who has made the aforementioned report shall besubject to any disadvantageous treatment on the basis of having made such report.
(2) Guarantee that the Audit Committee members selected by the Audit Committee may attend important
meetings and state their opinions from the viewpoint of legality, etc., when deemed necessary, andmay obtain important information.
(3) Bear expenses, etc., when the Audit Committee members request such expenses, etc., in accordancewith laws and regulations.
(4) Take measures to ensure that the Audit Committee is able to conduct its auditing activities effectively,
including coordination with the Internal Audit Department, financial auditors, and directors ofsubsidiaries.
(5) Upon request of the Audit Committee, the Representative Corporate Executive Officer, President andCEO shall conduct an investigation and report the results thereof to the Audit Committee. If the Audit
Committee deems it necessary in cases where the execution of duties by Corporate Executive Officers
is likely to violate laws and regulations or the articles of incorporation, etc., it may directly giveinstructions to the Internal Audit Department and such instructions shall have precedence over thoseof the Representative Corporate Executive Officer, President and CEO.