Compliance Declaration
March 24, 2023
ES-CON JAPAN Ltd.
Takatoshi Ito, President &Representative Director
The ES-CON JAPAN Group has made compliance management a top priority and is committed to corporate
activities rooted in compliance through honest, fair, and highly transparent behavior in accordancewith social norms. Under these circumstances, we deeply regret and accept with great seriousness theadministrative disposition taken by the Financial Services Agency in July of last year due toinappropriate behavior at ES-CON ASSET MANAGEMENT Ltd.
Based on this administrative disposition, the ES-CON JAPAN Group will continue to be an enterprisethat respects compliance management with utmost importance, and we declare that we will observe thefollowing Compliance Code of Conduct in order to fulfill our corporate social responsibility topractice Compliance Management.

Compliance Code of Conduct

1

We are aware of our corporate social responsibility and will contribute to the realizationof an affluent and comfortable society and earn the trust of society by providing safe, highquality products based on the diverse knowledge we have cultivated in the real estate fieldand other areas.

2

We will actively work to protect the global environment and strive to reduce the environmental
impact of all of our business activities, including the promotion of resource and energy
conservation, the reduction, reuse, and recycling of waste materials, and the prevention ofglobal warming.

3

We will be conscious that ensuring safety and health is an important corporate social
responsibility, and we will always act with safety and health as the top priority in allprocesses related to our business activities, including ensuring safety during construction
and maintaining the health of our employees.

4

We will respect the human rights and personalities of individuals and strive to create afair and healthy work environment, both inside and outside the company, free fromdiscrimination and harassment on the basis of race, ethnicity, origin, religion, creed, gender,disability, disease, or other factors. In particular, we will take a strict stance towardharassment in order to eliminate it.

5We will respect the diverse personalities of the members of our group, and through theformation of a free and open-hearted workplace where each individual can make full use of
his or her abilities and the fair treatment of our personnel, we will cultivate a sense ofmutual trust among our members and strive to create a workplace that is rewarding to workin.

6

We will always listen to the opinions of users and other customers, think from thecustomer's perspective, respond sincerely, and strive to provide safe, high-qualityproducts.

7

Based on the basic understanding that all of our business partners are partners in theexecution of our business, we will foster relationships of mutual trust through fair andequitable transactions.

8

We will never make illegal political contributions, offer or receive benefits, or bribe
politicians or public officials, and will always maintain sound and transparent
relationships with politicians and government administrations.

9

We will take a firm stand against antisocial forces that threaten social order and soundcorporate activities. We will not engage in any illegal or antisocial activities, and will
not provide or accept benefits of any type, including economic benefits, to or from antisocialforces.

10

We will always perform our duties with the highest ethical standards and social good sense,and will comply with all applicable laws and regulations, socially recognized standards andrules, contracts and promises exchanged with customers, business partners, local
communities, etc., company rules, and manuals related to our business activities, both
domestic and overseas.

11

We will strive to develop innovative technologies, products, and services and to obtainrights for and commercialize such technologies, products, and services, and in the process,we will not infringe on intellectual property rights, such as patents, utility models,designs, trademarks, and copyrights owned by third parties

12

Personal information concerning employees, business partners, and other third parties
obtained in the course of business will be kept under strict control and will not be disclosed
or divulged to third parties or to any person within the company who does not need suchinformation to perform their duties, except with the prior consent of the person concerned,
nor will such information be used for purposes other than those for which it was originallyintended.

13

Trade secrets, technical know-how and other confidential information concerning companiesor third parties obtained in the course of business will be kept under strict control, andwill not be disclosed or divulged to third parties or to any person within the company whodoes not need such information to perform their duties without permission, nor will suchinformation be used for any purpose other than its original purpose.

14

In our relationships with business partners and affiliated companies, we will not engage
in any conduct that might cause misunderstandings, such as offering or receiving
entertainment, gifts, or other favors beyond what is customary in social interaction orthat are considered excessive under socially accepted norms.

15

We have to use company assets or expenses, whether tangible or intangible, in order toaccomplish our business purposes, and will not use them for private purposes.

16

We will use the company's computer systems only for business purposes approved by thecompany in accordance with relevant internal regulations, and will not commit any unlawfulacts such as unauthorized intrusion into computer systems, damage, falsification, oralteration of data, or unauthorized use of computer software.

17

We will not use our position or authority in the course of our duties, or information
obtained in the course of our duties, to improperly benefit ourselves or third parties, andwill not engage in any activities that may compete with the Company's business without theCompany's permission.

18

We will not engage in canvassing for political or religious organizations, election
voting requests, or any other political or religious activities in the workplace without
the Company's permission.

19In order to abolish empty formalities, we will not give or receive gifts or othercommunications to or from individuals within the Company or among Group companies, except
for those that are socially acceptable.

20

We will deepen our understanding of the cultures and customs of the countries and regions
where we conduct our business activities, respect their social norms, and as good corporate
citizens, strive to live in harmony with local communities by participating in activities
that contribute to society.

21

As a corporate group that is open to society, we will maintain transparency in our businessactivities, disclose information appropriately, and strive to promote public understandingof our corporate activities. Furthermore, we will accurately and appropriately disclose
management information, including the status of the Company's financial position and businessactivities, to shareholders, investors, and other stakeholders in accordance with applicablelaws and regulations.

22

We will maintain a work environment in which all issues can be openly discussed, and if webecome aware of any conduct or potential conduct within the Company that violates laws andregulations or this Code of Conduct, we will not conceal or overlook such conduct, but willreport it to the Company via the compliance hotline or through the management system, in orderto resolve the issue.