SOLASTO GROUP CODE OF CONDUCTThe Group aims to earn the trust of customers and contribute to the creation of a sustainable
society by providing useful and advanced services to people. Based on these goals and theGroup's corporate philosophy, this Code of Conduct sets forth the standards which the Group's
officers and employees should abide by in making decisions and conducting themselves on adaily basis.

Chapter 1

Basic Policy

1. (Respect for Fundamental Human Rights)(1)
The Group and its officers and employees are committed to respecting fundamental
human rights and individual dignity in all business activities, and will not be complicit
in human rights abuses.
(2)
If any of the Group's operations, products or services are found to have a negative impact
on fundamental human rights, the Group and its officers and employees will address theissue in good faith.
2. (Respect for Diversity)
The Group and its officers and employees believe that the active participation of personnel withdiverse values and views is essential to the sustainable and sound development of the Group,
and are committed to respecting each other's personal characteristics, and completely
eliminating discrimination based on race, gender, social status or other such factors.
3. (Compliance with Laws and Regulations)
The Group and its officers and employees will comply with the laws, regulations and rules
applicable to them in all business activities, and will try to act in a restrained manner inaccordance with social ethics.

Chapter 2

Workplace and Working Environment

1. (Compliance with Laws and Regulations Concerning Working Conditions andOccupational Safety and Health)(1)
The Group will comply with the Labor Standards Act, the Industrial Safety and Health
Act, and other labor-related laws and regulations, and will work to maintain andimprove the working environment on a sustainable basis so that its officers andemployees can work safely and with a sense of security.
(2)
Under no circumstances will the Group engage in child labor, any form of forced labor,
abuse or corporal punishment that is prohibited by the laws and regulations of Japan andother countries and regions. In addition, the Group will limit the employment of young
workers to the extent permitted by applicable laws and regulations, and will assign them
only to tasks that do not expose them to danger.
12. (Improvement of Safety and Health in Workplace and Work-Life Balance)(1)
The Group will develop a system for the planned promotion of occupational healthmeasures to prevent occupational injuries and to maintain and promote the mental andphysical health of its officers and employees.
(2)
The Group attaches importance to work-life balance. The Group will develop a systemthat allows for more flexible work styles so that its officers and employees can balance
work with child care, nursing care, medical treatment or other such needs.
3. (Prevention of Harassment)(1)
The Group and its officers and employees understand that harassment undermines the
dignity of individuals and has a material adverse effect on the operation of theorganization. The Group and its officers and employees will not participate in or
overlook harassment in the workplace.
(2)
The Group will respond sincerely, but firmly, to customers harassing its officers andemployees.
(3)
In order to achieve the provisions of the preceding two paragraphs, the Group will
establish and operate a system to prevent harassment, and prepare and disseminate
harassment-related regulations.
4. (Equality of Wages and Opportunities)(1)
The Group will never engage in any unreasonable discriminatory practices with regard
to job application conditions or treatment of its officers and employees, will comply
with the Act on Equal Opportunity and Treatment between Men and Women in
Employment, the Act on the Promotion of the Employment of Disabled Persons, andother laws and regulations, and will not discriminate against any person on the basis ofgender, disability or other such factors.
(2)
The Group adheres to the principle of equal pay for equal work.
(3)
In order to achieve the provisions of the preceding two paragraphs, the Group will
establish a fair personnel and treatment system, and operate the system in an appropriatemanner.
5. (Human Resource Development and Support for Career Formation)
The Group believes that, in order to realize the sustainable growth of the Group, it is important
to bring out the abilities of its respective officers and employees through the human resource
development that takes into account their personal characteristics, aptitude and autonomy. To
this end, the Group will provide necessary support.

Chapter 3

Business Activities

1. (Engagement in Sound Economic Activities)
The Group and its officers and employees are committed to respecting others in their businessactivities, both inside and outside the Group, and will consciously act with integrity andresponsibility.
22. (Fair, Transparent and Free Competition; Fair Transaction)(1)
The Group and its officers and employees believe that fair, transparent and freecompetition is essential to the sustainable development of the society and economy,
including the Group, and will comply with the competition laws and other applicablelaws, regulations and guidelines.
(2)
The Group and its officers and employees will never engage in cartel activities, such as
price fixing or price restriction among competitors, market allocation or output
restriction, or bid rigging.
(3)
The Group and its officers and employees will not engage in any conduct that
unreasonably restricts, burdens or limits the business activities of business partners,
such as resale price restriction or tying, or unilateral changes in transaction terms orforced purchases through the use of a dominant position.
(4)
The Group and its officers and employees are fully aware of the conduct described in
the preceding two paragraphs, and will take the utmost care to prevent such conduct. Ifsuch conduct is suspected, it must be reported promptly to the Legal Department.
3. (Appropriate Promotional and Advertising Activities)(1)
The Group and its officers and employees believe that engaging in appropriate
promotional and advertising activities is essential to the sustainable development of theGroup, and will comply with all laws, regulations and guidelines relating torepresentations.
(2)
In advertisements and other materials, the Group and its officers and employees will
make reader-friendly representations that are factual and objective, and will not engage
in any promotional or advertising activities that use false or exaggerated advertising orother deceptive means.
(3)
The Group and its officers and employees will not use any expressions that defame orlibel others, or terms that may lead to social discrimination in any documents or othermaterials issued in promotional or advertising activities.
4. (Conclusion of Contract)(1)
When entering into a transaction with a customer or business partner, the Group and its
officers and employees will endeavor to prepare written agreements (including written
orders and other such forms) in a timely manner, and to enter into contracts with such
written agreements.
(2)
The Group and its officers and employees will comply with applicable laws andregulations (including tax laws) when doing business with customers or business
partners.
5. (Relationship with Suppliers)(1)
The Group and its officers and employees recognize that cooperation with and support
from suppliers are essential to the Group's business activities, and will endeavor to treat
suppliers fairly, and to maintain and build a long-term relationship of trust with suppliers.
(2)
The Group and its officers and employees will select suppliers in an appropriate and fairmanner after fully evaluating the quality, reliability, delivery dates and prices of thegoods supplied, the stability of management and the capacity for technologicaldevelopment of such suppliers, as well as whether such suppliers fulfill their social
responsibilities, including fair and highly transparent disclosure of information,
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compliance with laws, regulations and social norms, respect for human rights,
elimination of unjust discrimination in respect of employment and occupation,
elimination of child labor and forced labor, environmental protection activities, social
contribution activities, creation of a comfortable working environment, and sharing
awareness of social responsibility with business partners.
6. (Relationship with Stakeholders)(1)
The Group is listed on the Tokyo Stock Exchange. In order to earn the trust ofshareholders, investors and other stakeholders, the Group will maintain and continuetransparent management, and will disclose corporate information appropriately andsufficiently.
(2)
Through communication with a wide range of stakeholders, the Group will seek tounderstand and reflect the needs and opinions of these stakeholders in its businessactivities.
7. (Restrictions on Entertainment and Gifts)(1)
The Group and its officers and employees will maintain a sound, normal, open and fairrelationship with the administrative authorities, and will not entertain or provide gifts toofficers (including former officers) of public bodies such as government agencies andlocal governments, or to foreign public officials (including former public officials),regardless of whether such entertainment or gifts are prohibited by law or regulation.
(2)
The Group and its officers and employees will not provide customers or business
partners with improper profits, such as bribes or kickbacks, or with financial or otherbenefits.
(3)
The Group and its officers and employees will not accept or provide entertainment, gifts,
gratuities or other personal benefits that exceed what is appropriate under generally
accepted social norms.
8. (Prohibition of Involvement in Antisocial Forces)(1)
The Group and its officers and employees will take a firm stance against anti-social
activities and anti-social forces, and will not engage in such activities or forces,
including business relationships.
(2)
Prior to entering into a transaction, the Group and its officers and employees will
endeavor to thoroughly investigate whether the relevant counterparty is an anti-social
force or organization.
(3)
The Group and its officers and employees will develop a system to prepare for asituation in which an anti-social force seeks relations with the Group or its officers or
employees, or makes an unreasonable demand or request. If the Group or its officers or
employees actually receive such a demand or request, they will take a firm stance andrespond firmly to such demand or request, while cooperating with police authorities andrelevant organizations.
9. (Overseas Business Activities)
In overseas countries or regions, the Group and its officers and employees will endeavor tounderstand and act with respect for the differences in cultures, customs and languages in therespective countries and regions.
4Chapter 4

Security and Crisis Management

1. (Management of Confidential Information)(1)
The Group and its officers and employees will protect any information obtained from
customers and business partners, and any other information as confidential, and prevent
any leakage, loss or other incident.
(2)
If the Group or its officers or employees receive confidential information from a third
party or disclose confidential information to a third party, they will take appropriate
measures in advance, such as entering into a confidentiality agreement.
2. (Management of Personal Information)(1)
The Group and its officers and employees are fully aware of the confidential andsensitive nature of the personal information they handle in the course of their business,
and will comply with the Personal Information Protection Act and other relevant laws,
regulations and codes.
(2)
The Group and its officers and employees will process any personal information within
the scope of the purpose of use expressly indicated by the relevant individual. In
addition, the Group and its officers and employees will not disclose or make available
to third parties any personal information received without the consent of the relevant
individual or without a legitimate reason.
3. (Crisis Management)
Even under normal circumstances, the Group will thoroughly implement organizational crisis
management in preparation for any threats such as terrorism, cyber-attacks and natural disasters.
4. (Cybersecurity)(1)
The Group and its officers and employees recognize that cyber-attacks and other such
incidents are a risk factor that may have a significant impact on the management of theGroup, and will take measures to prevent damage from such attacks and develop asystem to minimize any damage that may occur.
(2)
The Group will promote an understanding of cybersecurity among its officers andemployees, and make efforts to cultivate the skills necessary for early detection,
response and recovery.

Chapter 5

Assets and Property of the Group

1. (Management of Corporate Assets)(1)
The Group and its officers and employees will properly manage and preserve theGroup's property in accordance with the rules, and will not use it for any purpose otherthan business.
(2)
Officers and employees will not seek personal gain through the use of the Group's
property.
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2. (Management of Intellectual Property)(1)
The Group will encourage activities to create intellectual property, which is an importantmanagement resource for the Group, and will work to protect, utilize and enhance thevalue of such intellectual property.
(2)
The Group and its officers and employees are committed to respecting the intellectual
property rights of third parties in the performance of their duties, and will not infringe
such intellectual property rights.

Chapter 6

Decision-making

1. (Decision-making Process)(1)
When making a business decision, the Group will evaluate objective facts fairly andimpartially, and make such a decision after being convinced that it is the best choice for
the Group.
(2)
In making a business decision as described in the preceding paragraph, the following
conditions must be met:i)
The decision is consistent with applicable laws, regulations and rules, as well asinternal rules and policies;
ii)
There is no personal interest or self-dealing involved;iii)
The decision is within the scope of authority granted by the Company;iv)
The decision is made with due care after making a reasonable effort to become
familiar with the relevant facts; andv)
The decision is made after good faith consideration and in the reasonable belief
that it is the best choice for the Company.
(3)
The Group will endeavor to maintain and improve its decision-making system so thatno decision is made that is inconsistent with the preceding two paragraphs.
2. (Lawful and Appropriate Record Keeping and Reporting)(1)
The Group and its officers and employees will faithfully and accurately prepare andmaintain books of account and financial records in accordance with the Financial
Instruments and Exchange Act, the Companies Act, and other applicable laws andregulations.
(2)
Officers and employees will not create inaccurate, misleading or false records.

Chapter7

Ethical Behavior of Officers and Employees

1. (Avoidance of Conflicts of Interest)(1)
Officers and employees are aware that any perceived conflict of interest could
undermine the confidence in fair business practices and adversely affect the Group'sbusiness, and will avoid any situation in which their interests conflict with those of theGroup, even if they have no improper purpose.
(2)
In the event of a potential conflict of interest between the Group’s officer or employee
and the Group, the officer or employee will promptly and accurately report the details
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of such conflict to his or her supervisor in accordance with the internal rules, and seek
the supervisor's decision and instructions.
2. (Separation of Public and Private Affairs)(1)
The Group encourages its officers and employees to voluntarily participate incommunity activities. However, they must keep in mind the separation of public andprivate affairs, and if they intend to participate in such community activities as officers
or employees of the Group, they must first obtain the permission of their supervisor inaccordance with the internal rules, and follow the supervisor's instructions.
(2)
The Group's officers and employees will not engage in any political, religious or private
business activities during working hours.
3. (Use of Media and Other Channels)(1)
The Group recognizes that the appropriate use of the media and other such channels(including so-called social networking services (SNSs); hereinafter the same) is
beneficial as a means of communicating information about the Group. Whencommunicating through the media or other such channels, the Group will pay due
attention to the language used and the content.
(2)
When the Group's officer or employee contacts the media or other such channels for oron behalf of the Group, or responds to inquiries from the media or other such channels,
he or she must always do so through the department in charge of public and investor
relations or other persons authorized by the relevant internal rules.
(3)
When the Group's officer or employee makes a statement about the Group as anindividual to the media or other such channels, the officer or employee will comply withthe relevant internal rules, and will not give the impression that he or she is expressing
opinions on behalf of the Group. In addition, if an officer or an employee finds anegative opinion about the Group or a post that requires a response, the officer or
employee will refrain from responding directly to the post, but will report it to thedepartment in charge of public and investor relations and the legal department, and ask
them to deal with it.
4. (Prohibition of Insider Trading)
The Group and its officers and employees will not use any information that could have amaterial impact on the price of the Group's stock or the stock of other companies to buy or sell
stocks or other securities before such information is made public (insider trading), nor will theytake any action toward a third party that could induce insider trading.

Chapter 8

Addressing Social Problems

1. (Addressing Social Problems)(1)
The Group will contribute to the development of local communities by providing
services such as medical administration, nursing care and child care, and by creating awide range of jobs.
(2)
The Group will create innovation through the use of data, contributing to the sustainableeconomic growth and solving social problems.
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(3)As members of the local community, the Group's officers and employees will work tocontribute to the development of the local community through volunteer activities andparticipation in local events.

2. (Environmental Consideration)
The Group and its officers and employees recognize that initiatives to address environmental
problems are important management issues. In addition to conducting business in anenvironmentally conscious manner, the Group and its officers and employees will comply withall environmental laws and regulations, and regional agreements, and will voluntarily work to
use resources effectively and to conserve resources and energy.

Chapter 9

Practicing Code of Conduct

1. (Operational Structure)(1)
The Board of Directors of the Group will establish an effective governance system toensure that this Code of Conduct is embedded in the Group and continuously improved.
Under this system, the Board of Directors of the Group will take the lead in familiarizing
all its officers and employees with this Code of Conduct.
(2)
The Board of Directors of the Group will share the philosophy underlying this Code of
Conduct with its stakeholders, and seek their cooperation in putting it into practice.
2. (Whistleblowing Contact Point)(1)
In connection with this Code of Conduct, the Group will establish a point of contact for
its officers and employees to report violations of laws and regulations in the course ofbusiness and performance of duties, and to make inquiries or seek guidance in cases
where they are unable to determine what action to take.
(2)
The Group's officers and employees will report to the point of contact identified in thepreceding paragraph if they have seen or heard of any illegal or non-compliant acts, orif they suspect that other officers or employees are involved in such acts.
(3)
In addition to the preceding paragraph, the Group will develop and maintain a system
for the early detection and prevention of misconduct on an ongoing basis.
(4)
The Group will give due consideration to the anonymity of any officer or employee of
the Group who has reported misconduct or who has cooperated in an investigation of
misconduct. The Group will treat the relevant officer or employee fairly andappropriately, and will not treat the officer or employee less favorably because he or she
has made such a report or has cooperated.
(5)
The Group will not tolerate, and will take strong action against, anyone who has
obstructed the reporting of misconduct by the Group’s officer or employee or thecooperation in an investigation of such misconduct.

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