Introduction

Compliance
Efforts to prevent corruption
Anti-Corruption Policy
4. Proper Accounting
The IDEC Group complies with applicable accounting laws, regulations, andstandards, conducts proper accounting under appropriate internal control systems,
and conducts as well as maintains transparent accounting reports, controls, andrecords to confirm and objectively prove that no misconduct has occurred.

2. Compliance with Applicable Laws and Regulations

The IDEC Group takes a strict stance against corruption, and if any IDEC Groupofficer or employee violates this policy or any applicable anti-corruption laws orregulations, we will take action in accordance with our internal rules. In addition,
if a business partner commits an act of corruption, a review that includes thecancellation of transactions with the business partner will be conducted.

The IDEC Group complies with anti-corruption laws and regulations that areapplicable in the countries and regions where it operates.

3. Prohibited Acts

Political contributions: 0 yen

The IDEC Group prohibits, directly or indirectly, the giving, offering, or exchangeof bribes, or the provision of benefits, whether domestic or international, including
the following: isciplinary dismissals forD
involvement in corrupt practices: 0
Number of serious legal violations: 0
Number of harassment reports and consultations: 4

 ribery of or the provision of benefits to public officials and others in similar positions
B
in the country or region where they conduct business.
 ribery of or the provision of benefits to a private citizen when such acts are prohibitedBby laws and regulations.

https://us.idec.com/governance/compliance ther matters prohibited by laws and regulations related to anti-corruption applicableOin the country or region where the business is conducted.

7. Management and Monitoring System
The IDEC Group strives to operate the IDEC Hotline, which is set up as an internalreporting hotline, in a fair and impartial manner, and will maintain a system thatenables the early and appropriate detection and monitoring of corruption andrelated acts.
In addition, when a report has been received through our hotline, the Risk
Management Committee sends the report to the Board of Directors, which reports
on risk monitoring activities twice a year through the Sustainability Committeeand is supervised by the Board of Directors.

Data andCompany Overview

51 IDEC Report 2024

Having relationships as well as engaging in business with antisocial forces.

6. Responses to Violations

Foundation for
Value Creation

Demands for illicit bribes or profiteering in business activities.
More information is available here.

The IDEC Group strives to properly educate and enlighten its officers andemployees on the prevention of corruption.

Business Strategy

Bribery-related fines, penalties, or settlements: 0 yen

5. Education and Enlightenment

Initiatives for
Realization of Vision

1. Basic Approach
The IDEC Group has established “The IDEC Way” as a new philosophy with theaim of becoming a truly global company. One of the Core Values that we must
share, as stated in “The IDEC Way,” is “Integrity,” which means that we should
face everything with sincerity and act with honesty and fairness to continue beinga trusted entity.
Recognizing that acts of corruption such as bribery, illegal gratuities, andprofiteering in our business activities have an impact on the fair and sustainable
development of society, we will work to prevent corruption throughout the Groupthrough the implementation of “The IDEC Way” and the “IDEC Group Code ofConduct,” in light of the call on global companies to take action against corruption.

Value Creation Story

FY2024 (consolidated)

Message

To prohibit corrupt practices such as bribery and ensurecompliance, we have established the IDEC Group Code ofConduct. It clearly states that we will not engage in any actsof bribery, unfair profiteering, dishonesty, fraud, other acts ofcorruption, extortion, or embezzlement, and will not engage
in business transactions or any kind of relations whatsoever
with anti-social forces.
We have also established an Anti-Corruption Policy thatspecifies and prohibits prohibited acts such as bribery inmore specific terms.
Through our internal whistleblowing system and risk
monitoring activities, we have established a system thatenables us to detect prohibited acts such as bribery, either
before they occur, or as soon as possible after they occur.

Introduction

Compliance

Establishment of Code of Conduct

Consultersand informants(head office and groupcompanies in Japan)

Number of trainees (%)

Consultationand reporting

Response
notification

Training on the subcontracting act

290 / 290(100%)(overseas groupcompanies)

Instruction
and reporting

Collaboration

Risk Management
Committee
Hotline Contact
External
contact venue(Web/phone)

Consultation
and reporting

Receipt
notification(Web)

Investigation, response,and corrective action

Response
notification
to eng f f ic
r ti d oop a
Re e heth

Global Hotline
Response
notification

Lawyer firm

Reporting tothe group company

Direction, reporting,and collaboration

Overseasgroup companies
Hotline Contact

Reporting

Investigation, response,and corrective action
Data andCompany Overview

1,189 / 1,189(100%)

4Foundation forValue Creation

52 IDEC Report 2024

Anti-harassment training(for non-managers)

Consulters
and informants

6(e-mail/mail)1,356 / 1,356(100%)
167 / 167(100%)

8Internalcontact venue

External contractors

Anti-harassment training(for managers)

FY2024

Business Strategy

Compliance training

Responsereporting

FY2023Inside Directors

IDEC Hotline
Consultation
and reporting

FY2022

Initiatives for
Realization of Vision

Details of training

Internal reporting system diagram

Number of internal reports (consolidated)
Value Creation Story

Compliance training in FY2024 (Japan)

The IDEC Hotline has been established as a hotline that allows
users to report compliance violations via either an internal orexternal contact point, and either anonymously or using real
names. We have established internal reporting and operation
rules to protect the confidentiality of consultation and reporting,and to prohibit unfavorable treatment of whistleblowers.
When a report is made, the Hotline Contact establishedwithin the Risk Management Committee promptly responds to
the report, and works at resolving the problem and preventing
recurrence. The report is also promptly communicated tothe top management, and regularly reported to the Board ofDirectors to share risk information. In cases where management
may be involved, a system exists to ensure independence andto liaise with an external law firm.
To enable the system to function globally, we haveestablished a Global Hotline which enables overseas Group
company employees to report directly to the head office contact.

Board of Directors

We conduct compliance training for all employees andposition-based training for promoted employees on a regularbasis, with the aim of helping them to acquire knowledge
and fostering compliance awareness with regard to humanrights, compliance with competition and subcontracting act(formally, the Act against Delay in Payment of Subcontract
Proceeds, etc. to Subcontractors), anti-bribery, the IDEC
Hotline (whistle-blowing system), and the protection of
personal data.
In each training session, we seek to deepen understandingof the IDEC Group Code of Conduct, and continuously conductcase studies of compliance related to our operations.
We conducted harassment and compliance training
for employees at our head office and Group companies inJapan in FY2024. As an individual compliance theme, we
conducted training on the subcontracting act, to enable
employees involved in subcontracting transactions to deepentheir understanding of the various obligations and prohibitions
that are required in practice. We will continue to provide training
and education, and continue to communicate information tofurther instill compliance awareness.
As part of our internal audits, we also conduct audits tocheck for compliance violations and appropriately recognize
the risks associated with neglect or violations of compliance.

Internal reporting system

Message

We have established an IDEC Group Code of Conduct, whichsets out the compliance and corporate philosophy for all IDECGroup employees in Japan and abroad with regard to humanrights, society, ethics, anti-corruption, and the environment,etc., and defines basic global conduct guidelines for performing
their duties.
In addition to Japanese and English, the Code of Conduct
has been translated into Chinese, French, Thai, Vietnamese,and Khmer languages, and published on the Group intranet.
These are available for viewing by employees of Group
companies both in Japan and overseas at any time.

Compliance training and audits