Note: This document is an English translation of the original Japanese language document and has been prepared solely
for reference purposes. No warranties or assurances are given regarding the accuracy or completeness of this English
translation. In the event of any discrepancy between this English translation and the original Japanese language document,
the original Japanese language document shall prevail in all respects.

Corporate Governance
CORPORATE GOVERNANCE

freee K.K.

Last Update:

October 3, 2023

freee K.K.
Daisuke Sasaki, CEO and Representative Director
Contact: Corporate Division
Securities code: 4478

The status of corporate governance of freee K.K. (the “Company”) is as described below.

I.

Basic Policies on Corporate Governance, Capital Structure, Company Attributes, and Other
Basic Information

1.

Basic Policies
Pursuant to our mission, “Empower Small Businesses to Take Center Stage,” the Company’s group recognizes our corporatesocial responsibility and makes efforts to contribute to society through various services and bring harmonized benefits to ourstakeholders. Thus, the Company will promote a monitoring system for business execution and disclose information in a timely
manner in order to ensure transparency and objectivity in our business activities for the development of appropriate corporate
management systems.

Rationale for Not Implementing Principles of the Corporate Governance Code
The Company has implemented all five basic principles of the Corporate Governance Code.

2. Capital Structure
Foreign Shareholding Ratio

30% or more

Major Shareholders Updated
Name or Designation

Number of Shares Owned

Ratio (%)

Daisuke Sasaki

11,054,662

19.11

MSIP CLIENT SECURITIES

6,244,312

10.79

GOLDMAN SACHS & CO.REG

4,155,615

7.18

MSCO CUSTOMER SECURITIES

2,945,481

5.09

INTERACTIVE BROKERS LLC

2,437,300

4.21

Recruit Co., Ltd.

2,277,267

3.94

Ryu Yokoji

2,042,662

3.53

NOMURA PB NOMINEES LIMITED OMNIBUS-MARGIN (CASHPB)

1,586,061

2.74

THE BANK OF NEW YORK MELLON 140051

1,197,700

2.07

STATE STREET BANK AND TRUST COMPANY 505303

1,070,000

1.85

Controlling Shareholders (excluding Parent
Company)―

Parent Company

Not applicable

Supplementary Explanation―

3.

Company Attributes
Listing Market Classification
Term-End
Category of Business(Consolidated) Number of Employees as ofPreceding Term-End Updated(Consolidated) Revenue as of Preceding Term-End
Consolidated Number of Subsidiaries as ofPreceding Term-End

4.

TSE Growth
June
Information and telecommunication
1,000 or more
10~100 billion JPY
Less than 10 companies

Guidelines for Protection of Minority Shareholders in Transactions with Controlling Shareholders―

5.

Other Special Circumstances That May Have a Material Impact on Corporate Governance―II.

Corporate Management Organization and Other Corporate Governance Matters Related
to Decision Making, Business Execution, and Supervision in Corporate Management

1.

Organizational Structure and Operations
Organizational Form

A company with an Audit & Supervisory Committee

Matters Related to Directors
Maximum Number of Directors Stipulated in the
Articles of Incorporation
Term of Office of Directors Stipulated in the
Articles of Incorporation

14
1 yearChairperson of the Board
Number of Directors

CEO
7

Appointment of Outside Directors
Number of Outside Directors

Appointed
4

Number of Independent Directors

42

Relationship with the Company (1) Updated

Name

Relationship with the Company (*)

Attribute

Yoko Naito

From another company

Masao Hirano

Academic

Shinji Asada

From another company

Yumi Hosaka Clark

From another company

a

b

c

d

e

f

g

h

i

j

k

△

* Categories of “Relationship with the Company”* ○: shows the item is/was applicable to the outside director either currently or until recently;△: shows the item was applicable to the outside director in the past
* ●: shows the item is/was applicable to a close relative of the outside director either currently or until recently;▲: shows the item was applicable to a close relative of the outside director in the pasta. An executive of the Company or its subsidiaryb. A non-executive director or executive of a parent company of the Company
c. An executive of a fellow subsidiary of the Company
d. A party whose major client or supplier is the Company or an executive thereof
e. A major client or supplier of the Company or an executive thereof
f. A consultant, accountant or legal professional who receives a large amount of monetary consideration or other property from theCompany besides compensation as an officer
g. A major shareholder of the Company (or an executive of the said major shareholder if the shareholder is a corporation)h. An executive of a client or supplier of the Company (which does not fall under any of d, e, and f) (the Director himself/herself
only)
i. An executive of a company to and from which outside officers are mutually appointed (the Director himself/herself only)
j. An executive of a party that receives a donation from the Company (the Director himself/herself only)
k. Other3

Relationship with the Company (2) Updated

Name
Yoko Naito

Member of
Audit &
Supervisory
Committee○

Designation
as an
Independent
Director○

Supplementary Explanation of
the Relationship―――

Reasons for Appointment
Ms. Naito has profound insight asa certified public accountant.
Having served as a full-time
Audit & Supervisory Board
Member since 2018 and a fulltime Audit & Supervisory
Committee Member since 2021,
she has attended importantinternal meetings such as those of
the Management Meeting and the
Risk Management Committee,
held hearings with executives andemployees,
andactivelymonitored the execution ofbusiness of the Company. She isexpected to fulfill her role,
includingprovidinghighlyeffective supervision of the
management of the Company,
from an independent andobjective standpoint as an
Outside Director who is an Audit&
Supervisory
Committee
Member.
She is unlikely to have conflictsofinterest
withgeneralshareholders because she falls
under none of the judgment
criteria regarding independence.

4

Name
Masao Hirano

Shinji Asada

Member of
Audit &
Supervisory
Committee○○

Designation
as an
Independent
Director○○

Supplementary Explanation of
the Relationship―――Mr. Shinji Asada was an
executive at Salesforce Japan
Co., Ltd. from February 2018 toMarch 2020. As the total amountof the Company’s transactions
with Salesforce Japan accounts
for about 1.9% of the Company’s
consolidated net sales and thetransactions
areordinarytransactions, there is no special
relationship between Mr. Asadaand Salesforce Japan. Taking into
account the nature of the business
transaction, Mr. Asada is deemed
to be sufficiently independentand unlikely to have conflicts ofinterest
withgeneralshareholders.

Reasons for Appointment
Mr. Hirano has deep insight into
corporate management, acquired
over many years as a management
consultant
anduniversity(business school) professor.
Additionally, he has a wealth ofexperience as a manager atbusiness companies,
consulting
companies,
andinvestment funds. He is expected
to fulfill his role, including
providing advice and highly
effective supervision of the
management of the Company
alongside strengthening corporate
governance, from an independentand objective standpoint as an
Outside Director who is an Audit&
Supervisory
Committee
Member.
He is unlikely to have conflicts ofinterest with general shareholders
because he falls under none of thejudgment
criteria
regarding
independence.
Mr. Asada has extensive insight
into the SaaS industry, acquired
over many years. As an Audit &Supervisory Committee Memberof the Company, he actively
provides advice on a broad rangeof matters such as management
strategy,
investment,
andgovernance. He is expected tofulfill his role, including
providinghighlyeffective
supervision of the management oftheCompany,fromanindependentandobjective
standpoint as an Outside Director
who is an Audit & Supervisory
Committee Member.
While he was an executive of theCompany’s business partner, he
has already retired from thecompany and is unlikely to haveconflicts of interest with generalshareholders considering thetransaction size as stated in theleft column.

5

Name
Yumi Hosaka Clark

Member of
Audit &
Supervisory
Committee

Designation
as an
Independent
Director○

Supplementary Explanation of
the Relationship―――

Reasons for Appointment
Ms. Clark has served in key
positions at international fintech
companies, and has abundant
experienceindevelopment
linking traditional
financial
networks with the latest apps, aswell as post-development scaleup. She also has extensive
experience servicing the small
business segment, and investment
and corporate mergers. Thus, sheis expected to provide appropriate
advice on the management of theCompany from an objective andglobal perspective as an Outside
Director.
She is unlikely to have conflictsofinterest
withgeneralshareholders because she falls
under none of the judgment
criteria regarding independence.

6

Audit & Supervisory Committee
The Committee’s Composition and Attributes of Its Chairperson
Number ofCommittee
Members
Audit &
Supervisory
Committee

Number of Fulltime Committee
Members3

Appointment of Directors and/or Staff to Support the
Audit & Supervisory Committee

Number of Inside
Directors

Number of Outside
Directors

Chairperson

03Outside Director

1

No

Reasons for Adopting the Current System
Please refer to “IV.1.Basic Approach in Relation to the Internal Control System and the Progress of Development Thereof” below.

Cooperation among the Audit & Supervisory Committee, Accounting Auditors and Internal Auditing Department
The Audit & Supervisory Committee, Internal Auditors, and Accounting Auditors mutually cooperate and hold periodic meetings
to share information for issues and improvements, etc.
For improvement of audit effectiveness and efficiency, the Audit & Supervisory Committee receives reports from Accounting
Auditors on audit planning, performance, and results of their duties, etc. as necessary and exchanges information and opinionswith them. Also, auditors of the Audit & Supervisory Committee and Internal Auditors have meetings as necessary and makeefforts for effective auditing through a mutually complementary system and audit schedule adjustments.

Voluntary Establishment of Committee(s)Voluntary Establishment of Nomination Committee and/or
Remuneration Committee

Not established

Matters Related to Independent Officers
Number of Independent Officers Updated

4

Other Matters Related to Independent Officers
Every person eligible to be an Independent Officer has been appointed as an Independent Officer.
[Insignificance Criteria]
The Company omits the description and overview of applicable attribute information if transactions or donations associated withan outside officer fall within the following insignificance criteria.
(Transactions)- For the latest fiscal year, the payment amount from the Company is less than 1% of the payee’s annual consolidated net sales(including those equivalent) or less than JPY 10 million, whichever is lower.
- For the latest fiscal year, the payment amount to the Company is less than JPY 10 million.
(Donations)- For the latest fiscal year, the donation amount received from the Company is less than JPY 500,000.

Matters Related to Incentives
Status of Initiatives to Provide Incentives to
Directors

Introduction of a performance-based remuneration system / Introductionof a stock-option system / Others7Supplementary Explanation
A stock-option system to increase appetite and motivation toward greater business performance of the Company with the aim ofincreasing its medium- to long-term stock value, as well as a restricted share (RS) compensation plan and a performance-based
remuneration system for Directors (excluding Directors who are Audit & Supervisory Committee Members and Outside
Directors) has been introduced.
Persons Eligible for Stock Options

Inside Directors, Outside Directors, Employees, Others

Supplementary Explanation
The system has been introduced to increase appetite and motivation toward greater business performance of the Company among
the eligible persons listed above.

Matters Related to Director Remuneration
Disclosure status

Individual remuneration amounts are not disclosed.

Supplementary Explanation
Since no Director receives remuneration of JPY 100 million or above in total, remuneration amounts of individual Directors are
not disclosed. Total remuneration of Directors and Directors who are Audit & Supervisory Committee Members by officer types
are disclosed.
Policy on Determining Remuneration Amounts andCalculation Methods

Established

Disclosure of Policy on Determining Remuneration Amounts and Calculation Methods
For determination of remunerations for Directors (excluding the Directors who are Audit & Supervisory Committee Members),
the Company has established a compensation structure that offers sufficient incentives for sustainable growth in the corporate
value based on comparison of remuneration systems and standards of the Company and other domestic and international
enterprises of similar sizes and business categories, and has a basic policy of determining remunerations for individual Directors
appropriately in consideration of their roles and responsibilities. Specifically, the compensation structure consists of baseremunerations (monetary compensation) and stock options (performance based and restricted share compensations). However,
remunerations for Outside Directors (excluding the Directors who are Audit & Supervisory Committee Members) are baseremunerations (monetary compensation) only.
Remunerations for the Directors who are Audit & Supervisory Committee Members are monetary remunerations and restricted
share compensations only and have been determined through consultation among all the Directors who are Audit & Supervisory
Committee Members in consideration of their roles and responsibility and other circumstances such as economic situations, within
the remuneration limit resolved at the General Meeting of Shareholders.

Supporting System for Outside Directors (and Outside Audit & Supervisory Committee Members)
While no dedicated employees are allocated for services of Outside Directors, the Corporate Division arranges support asnecessary.

82.

Matters on Functions such as Business Execution, Auditing/Supervision, Nomination, and Remuneration
Decisions (Overview of the Current Corporate Governance System) Updated
a. Board of Directors and Composition of Officers
The Company’s Board of Directors is composed of four Directors (including one Outside Director) and three Directors who are
Audit & Supervisory Committee Members (including three Outside Directors) and authorized to make decisions on the
Company’s business execution and supervise execution of duties of the Directors. The Company has invited Ms. Yumi Hosaka
Clark, Ms. Yoko Naito, Mr. Shinji Asada and Mr. Masao Hirano as Independent Directors to promote establishment of ourmanagement organization that enables creation of values, management decision making, and management supervision fromoutside based on broader perspectives. Furthermore, the Company’s Board of Directors deliberates and reports on and resolves
legal and important management matters at the regular meetings of the Board, which are held monthly in principle, andextraordinary meetings of the Board, which are held as necessary, with attendance of the Directors and Directors who are Audit& Supervisory Committee Members.
b. Audit & Supervisory Committee
The Company has an Audit & Supervisory Committee. The Audit & Supervisory Committee consists of three Directors who are
Audit & Supervisory Committee Members: Ms. Yoko Naito (full-time), Mr. Shinji Asada (part-time), and Mr. Masao Hirano(part-time), all of whom are independent Outside Directors.
The Directors who are Audit & Supervisory Committee Members audit daily activities of the Directors including execution of
their duties. The Directors who are Audit & Supervisory Committee Members have provided objective opinions from an
independent and disinterested standpoint based on their expertise in financing and accounting as well as the SaaS industry. The
Directors who are Audit & Supervisory Committee Members engage in viable monitoring activities including attendance at theGeneral Meeting of Shareholders and Board of Directors meetings, exercise of their legal rights such as receiving reports fromthe Directors, employees, and auditing company. In addition, the Director who is a full-time Audit & Supervisory Committee
Member attends management meetings and other important meetings, and conducts visiting audits at the Company’s sites.
c. Internal Audit
The Internal Auditing Department (three persons), which is under the immediate supervision of the Company’s Representative
Director, is responsible for internal audits of the Company’s group. In order to ensure compliance with laws and regulations,reliability of financial reporting, and operational effectiveness and efficiency, the Internal Auditing Department conducts internal
audits based on an internal audit plan approved by the Representative Director, reports audit results to the Representative Director
and the Board of Directors, as well as the Audit & Supervisory Committee, and if identifying any deficiencies, presents findings
to relevant departments for corrections and improvements, and later verifies progress of improvements.
d. Accounting Auditors
The Company has concluded an auditing contract with KPMG AZSA LLC. There are no particular interests between the Company
and the auditing company and/or its employees who execute audits on the Company.

3.

Rationale for Adopting the Current Corporate Governance System Updated
The Company considers the enhancement and strengthening of our corporate governance structure as a significant managerial
priority, and is actively pursuing ongoing initiatives in this challenge. Amid the progressing globalization and complexity of the
management environment, to achieve sustainable growth in enterprise value, the Company has adopted a “company with an Audit& Supervisory Committee” system, which allows for a significant delegation of the executive decision-making authority of theBoard of Directors to executive directors, further enhanced discussions on corporate strategies and others within the Board of
Directors, and worked on strengthening the supervisory function of the Board of Directors. In addition, as stated above, theCompany has the General Meeting of Shareholders, Board of Directors, Audit & Supervisory Committee, and Accounting
Auditors and appointed a person responsible for internal auditing on daily operations. The Company believes this system
continuously increases our enterprise value and maintains the effective governance structure through mutual collaborations
among these organizations.

9

III.
1.

Status of Initiatives Related to Shareholders and Other Stakeholders
Initiatives to Facilitate the General Meeting of Shareholders and Exercise of Voting Rights Updated
Supplementary Explanation
Early Notification of General Meeting of
Shareholders

The Company makes efforts to send a convocation notice of the General
Meeting of Shareholders before the statutory deadline to enable shareholders
to exercise their voting rights based on their thorough consideration on
proposed matters. Additionally, the convocation notice is disclosed on the
Company’s website ahead of its sending. In the case of 2023, the Company sentout the notice three business days before the statutory deadline and disclosed it
on its website more than three weeks prior to the date of the General Meetingof Shareholders.

Scheduling General Meeting of Shareholders
to Avoid Peak TimeThe Company’s fiscal year ends every June and the General Meeting of
Shareholders is held every September, which is not a month where generalshareholder meetings of other companies are held in high concentration.
Exercise of voting rights via the Internet is allowed.

Electronic Exercise of Voting Rights
Electronic Voting Platform and Other
Initiatives to Promote Exercise of Voting
Rights by Institutional Investors
Provision of Convocation Notice (Summary)in English

2.

The Company considers participating in an electronic voting platform taking
into account changes in the shareholder structure.
The Company posts the notice in English on the IR section of Company’s
website as is the case with the Japanese version.

IR Activities Updated
Supplementary Explanation
Preparation and Publication of Disclosure
PolicyRegular Investor Briefings for Individual
Investors

The policy is disclosed on the IR section of the Company’s
website.
The Company recognizes that this matter should beconsidered in the future as necessary.

Regular Investor Briefings for Analysts andInstitutional Investors

The Company holds a financial results briefing foranalysts and institutional investors for each quarter inprinciple to explain financial results and management
policies.
The Company provides information to overseas investors
primarily on one-on-one investor meetings.

Regular Investor Briefings for Overseas
Investors
Disclosure of IR Materials on the Corporate
WebsiteDepartment (Person) in Charge of IR

3.

Explanation byRepresentative

No
Yes

Yes

The Company discloses IR materials on the IR section of
the Company’s website.
Department in charge: Finance strategy team, Finance
Division
Officer in charge: CFO

Status of Initiatives Related to Due Respect for Stakeholders
Supplementary Explanation
Establishment of Internal Rules for Due
Respect for Stakeholders’ Positions

Environmental Conservation and CSR
Activities, etc.

The Company believes it is critical to gain trust from various stakeholders
including shareholders, clients, and suppliers in expanding the business.
Furthermore, the Company has established a corporate management system forquick decision making and operational execution in response to changing
management environments while attempting to enhance the corporate
management system to endure management efficiency.
The Company discloses its ESG efforts toward achievement of a sustainable
society on the ESG section of the Company’s website.

Development of Policies on Information
Provision to Stakeholders

The Company has a policy of actively disclosing information to stakeholders
through our corporate website and financial results briefing.

10

IV.
1.

Matters Related to the Internal Control System
Basic Approach in Relation to the Internal Control System and the Progress of Development Thereof

Updated(Overview of the System to Ensure Properness of the Business Operations)
The Company has developed an internal control system pursuant to a basic policy on internal control system development.
Described below is the overview of the system.
- Overview of the Basic Policy for Development of the Internal Control System
a. System to Ensure Execution of Duties by Directors and Employees in Compliance with Applicable Laws and Regulations andthe Articles of Incorporation
The Company acknowledges that it is essential for continuation and development of the Company that all Directors andemployees behave in strict compliance with laws and regulations and at high levels of ethics.
(a) Directors behave in accordance with appropriate corporate ethics and social norms as a member of the society and strive to
conduct sound corporate management.
(b) Executive Directors execute their assigned duties based on appropriate decisions made by the Board of Directors and report
the status of execution thereof to the Board of Directors in an appropriate and prompt manner.
(c) The Board of Directors institutes policies regarding execution of duties, such as “Board of Directors rules” and “rules on
division of duties,” and Directors and employees execute their duties pursuant to the instituted rules and policies.
(d) The Company has instituted “compliance policies” and regularly convened the Compliance Committee chaired by the
Representative Director, where compliance matters within the Company’s group are reported and deliberated on. Additionally,
the Company is committed to continuous education and dissemination activities in relation to compliance.
(e) A whistle-blowing system is developed to facilitate the early detection of events that may constitute compliance violations
and to establish a framework for appropriate responses.
(f) A regular internal audit system is established to ensure operations in compliance with laws, regulations, the Articles ofIncorporation, and internal rules and policies, audit compliance with laws and regulations, reliability of financial reporting, andthe status of operational effectiveness and efficiency, and promptly report results to the Representative Director and the Board of
Directors, as well as the Audit & Supervisory Committee.
b. System for Storage and Management of Information Related to Execution of Duties by Directors
Documents related to execution of duties by Directors including minutes of the Board of Directors meetings and other important
meetings, contracts, and written requests for approval, etc. are kept in a hardcopy or electronic format and securely maintained
and managed pursuant to “document control rules.”c. Regulations and Other Systems Related to Management of the Risk of Losses
For significant risks and risks of losses associated with our business activities, the Company has instituted “risk management
rules” and regularly convened the Risk Management Committee to identify, assess, and monitor risks across the Company andthereby prevent risks from materializing. The Company will quickly and appropriately respond to any manifested risk under the
instruction of a risk management officer, and will minimize losses and damages arising out of the risk.
Furthermore, the Company strives to reduce legal risks through credit management by an external agency and cooperation withoutside legal counsels in responding to important legal issues.
d. Systems for Ensuring the Efficient Performance of Duties by Executive Directors
The Company holds a regular Board of Directors meeting monthly and proposes all relevant matters stipulated in the “Board of
Directors rules” and the “list of authorities” to the Board of Directors for resolution of important matters. Furthermore, the Boardof Directors regularly receives reports on the progress of execution of duties from each Director and supervises adequacy andefficiency thereof.
For routine execution of duties, the Company delegates authorities pursuant to provisions of the “rules on division of duties” andensures quick execution of duties by clarifying assignment of authorities and responsibilities. The Company also reviews theregulations as necessary and establishes a system that ensures appropriate and efficient execution of duties by Directors.
e. System to Ensure Properness of Business Activities of the Corporate Group Consisting of the Company and its Subsidiaries
In order to ensure management of risks of loss, efficient execution of duties of directors, execution of duties of directors andemployees in compliance with laws, regulations, and the Articles of Incorporation, and appropriate reporting on situations of
directors’ executions of their duties at subsidiaries, the Company takes the following actions.
(a) The Company dispatches the Company’s officers to its subsidiaries as Directors or Auditors of the subsidiaries and manages
and supervises business operations of the subsidiaries pursuant to the “affiliate management rules.”(b) The Company deliberates on important management decisions of subsidiaries in advance and receives ex post reporting.
(c) Internal auditors conduct audits on subsidiaries pursuant to the “internal audit rules.”(d) The Audit & Supervisory Committee of the Company receives reports and explanations about management of subsidiaries
from the Company’s Directors and employees, and requests business reporting or investigates the operational and financial status11

of subsidiaries as necessary.
f. Matters Related to Employee(s) Assisting in Duties of the Audit & Supervisory Committee
If needed, the Company may assign employee(s) to employee(s) assisting in duties of the Audit & Supervisory Committee .
g. Matters Related to Independence of the Said Employee(s) in the Previous Sentence from Directors (excluding Audit &Supervisory Committee Members) and Matters on Ensuring the Practicability of Instructions Given by the Audit & Supervisory
Committee to the Said Employee(s)Any employee(s) placed to assist in Audit & Supervisory Committee Members shall report only to the Audit & Supervisory
Committee Members in their duties and be held free from the reporting line under Directors (excluding the Audit & Supervisory
Committee Members) and other employees. For selection, transfer, and performance evaluation of the said employee(s), theCompany shall consult with the Audit & Supervisory Committee Members and give sufficient considerations to their
independence.
h. System Related to Reporting to the Audit & Supervisory Committee
Once becoming aware of any material breach of laws, regulations, and/or the Articles of Incorporation or any misconduct inbusiness operations under their charge or any fact that could lead to significant damage to the Company, Directors (excluding
Audit & Supervisory Committee Members) and employees will immediately report it to the Audit & Supervisory Committee. No
disadvantage will be imposed on Directors and employees who report any incident to the Audit & Supervisory Committee.
i. Matters Related to the Policy on Proceedings for Advance Payment and Reimbursement of Expenses Incurred for Execution of
Duties of the Audit & Supervisory Committee and Processing of Expenses or Liabilities Arising from Execution of such Duties
When the Audit & Supervisory Committee requests the Company for advance payment of expenses based on Clause 4 of Article399-2 of the Companies Act, a responsible department will validate and promptly process the expenses or liabilities unless therequested expenses and liabilities are proven to be unnecessary for execution of duties of the Audit & Supervisory Committee.
j. Other Systems to Ensure Effective Auditing by the Audit & Supervisory Committee(a) The Audit & Supervisory Committee shall have regular meetings with the Representative Director and exchange opinionswith the Representative Director on matters such as issues that the Company should address, risks surrounding the Company,
development of an appropriate environment for Audit & Supervisory Committee’s audits, and important issues in auditing.
(b) The Audit & Supervisory Committee shall cooperate and exchange information with Accounting Auditors and internal
auditors as necessary to ensure effective and efficient auditing.

2.

Basic Approach and Progress of Exclusion of Antisocial Forces(a) The Company has developed a manual for exclusion of antisocial forces and commits to thorough exclusion of antisocial
forces.
(b) The manual for exclusion of antisocial forces requires the Company’s officers and employees not to have any relationshipwith antisocial forces and organizations and to promote initiatives to clock such relationships. Furthermore, the Company deals
with antisocial forces and organizations in an organized manner with collaboration with attorneys and the police, etc.

12

V.

Other Matters

1.

Anti-Takeover Measures
Anti-Takeover Measures

Not establishedSupplementary Explanation―

2.

Other Matters Related to Corporate Governance Systems, etc.
―

[Schematic Chart (Reference)]

13

[Overview of the Timely Disclosure System (Schematic Chart)]

14