Compliance Policy

The Valuence Group (hereinafter, the “Group”), as a contributor to the sound development of the reuseindustry and as a public institution of society, we have a responsibility to create a fair and transparent
reuse market where customers can do business with peace of mind.
All of our corporate activities are based on the spirit of compliance, which each of our officers andemployees must practice independently. Practicing compliance does not simply mean not violating “laws,regulations, or rules” but also means “acting in accordance with high ethical standards.”
In order to carry out exemplary corporate activities as a reuse company, we have established theCompliance Code of Conduct, which is a common standard of judgment for each officer and employee,
ensuring that compliance is a top priority.

1. Action Guidelines
・ Gain the trust of society by acting with integrity based on high ethical standards.
・ Strictly comply with laws and regulations and carry out corporate activities fairly and honestly.
・ Strive to put the customer first.
・ Respect human rights and strive to create a favorable work environment.

2. Monitoring and Education
・ Based on an elevated level of ethical awareness, we consider situations that violate social norms asrisks to the entire business and have established a system to ensure thorough compliance inaccordance with internal rules.
・ In order to gain the trust of society, we have established a training and education system andthoroughly disseminated the knowledge and information necessary to practice compliance.

3. Compliance with Laws and Regulations
・ In order to contribute to the sound development of the reuse industry, we will correctly understandrelevant laws and regulations such as the Secondhand Articles Dealer Act and thoroughly comply
with rules.
・ In order to reduce the damage caused by crimes such as theft as much as possible, we will actively
cooperate with requests from the police and other investigative agencies. To prepare for the unlikely
event that stolen, copied, or otherwise illegal products are brought into the company, we have

established a system to report the incident to the investigating agencies promptly and strive to limit
the spread of damage from criminal activity.

4. Promotion of Fair Transactions
・ We will establish a sound business environment and conduct fair and transparent transactions sothat all stakeholders, including shareholders and customers, can feel secure in dealing with us.
・ In order to maintain a sound business environment, we will correctly understand the intentions of theAnti-Monopoly Act, the Subcontract Act, the Unfair Competition Prevention Act, and other laws andregulations that regulate unfair transactions, and respond to them in good faith.

5. Prohibition of Gifts, Entertainment, and Profit Sharing
・ We do not accept improper or inappropriate gifts, entertainment, or other benefits from any of ourbusiness partners. If there is a possibility of profit sharing, we will act sensibly within the scopepermitted by laws, regulations, and internal rules.
・ We do not provide improper or inappropriate gifts, entertainment, or other benefits to any of ourbusiness partners. Regarding providing or receiving entertainment or gifts to or from our business
partners, we will act in accordance with sound social common sense.
・ We do not demand improper or antisocial monetary kickbacks or similar benefits from our business
partners.
・ We do not demand preferential treatment for ourselves or our related parties.
・ We do not provide any entertainment or gifts to public officials in violation of the National PublicService Ethics Act, the National Public Service Ethics Code, or other similar regulations stipulated
by government agencies, as well as overseas public officials.

6. Efforts to Prevent Bribery and Corruption
・ Take strict measures to prevent corruption in all forms.
・ With regard to “facilitation payments” overseas, after analyzing regions and business activities witha substantial risk of occurrence, we will ensure that local employees are aware of the prohibition offacilitation payments and take this into consideration when selecting business partners.
・ Maintain sound and normal relationships with political, administrative, and regulatory authorities, andwill not make improper or inappropriate donations or contributions in violation of laws, regulations,or internal rules.

7. Money Laundering
・ We will not provide funds to anti-social forces.
・ In accordance with the Act on Prevention of Transfer of Criminal Proceeds, we will not be involvedin transactions involving proceeds from illegal activities, transactions that provide funds to terrorists,
or transactions with parties prohibited by governments, etc. If there is a possibility that a transaction
may fall under the category of suspicious transactions, we will provide appropriate notifications tothe authorities.

8. Response to Anti-social Forces
・ In accordance with the Declaration of Elimination of Antisocial Forces and the Rules for Dealing with
Anti-social Forces, we will firmly maintain our corporate stance of not having any relationships with
antisocial forces and will take a resolute stance in dealing with them.

9. Information Management
・ Strictly manage the company’s confidential information, customer information, and personalinformation, and will not leak such information to any third party or use such information for any
purpose other than the company’s business.
・ Handle confidential information disclosed by a third party in the same manner as the company’sconfidential information.
・ In order to protect investors, we will actively and fairly disclose corporate information in a timely
manner as required by laws and regulations or stock exchange rules.
・ In the event that we become aware of undisclosed material facts about our company or our businesspartners, we will not buy or sell their shares (insider trading) until such facts are made public.
・ We will not engage in unfair competition, including the improper acquisition or use of trade secretsof others.

10. Accounting Reports and Fulfillment of Tax Obligations
・ Properly manage the company’s funds and assets and use them only for legitimate businesspurposes, and do not hold off-the-books funds or assets.
・ We will always ensure the accuracy of our accounting reports and conduct them in a timely andappropriate manner in order to live up to the trust of stakeholders such as shareholders and investors.
We will not make any false or misleading entries in our books.
・ Comply with the tax laws of each country and fulfill our tax obligations appropriately and fairly.

11. Personal Information Protection
・ Based on the company’s Personal Information Protection Policy and Basic Rules for Personal
Information Protection, we will strive to establish a system to ensure that all officers and employees
are fully aware of the protection of personal information.
・ We will also act appropriately to comply with regulations related to the protection of personal
information overseas.

12. Internal Reporting System
・ The Group has established internal and external contact points for reporting (consulting) on
compliance issues, such as violation of laws, regulations, and internal rules. The privacy of those
who consult or report to these contact points is strictly protected, and the system is designed toprevent any disadvantage treatment to those who report or consult. Currently, there are two contact
points: the Internal Audit Office and an external law firm.
・ The department in charge investigates and responds to the reported cases, takes necessarymeasures such as implementing measures to prevent recurrence, and reports the results to the Risk
Management Committee and the Board of Directors.