Self-Imposed Code of Conduct for Multilevel Marketing Transactions

Introduction
This Self-Imposed Code of Conduct (hereinafter referred to as the "Guideline") was formulated by
the consensus of the members of of the Japan Direct Selling Association (hereinafter referred toas “Members''), and its purpose is to provide products, or services by having loyal buyers
participate in sales activities as independent business owners, and the form of business("multilevel marketing undertakings" defined in the “Act on Specified Commercial Transactions”(hereinafter referred to as the "Act") by conducting proper transactions and for the sounddevelopment of the industry, thereby gaining the correct understanding and awareness of
consumers and others, and enhancing the evaluation of the business in society.

This business format, in which loyal buyers of products are involved in sales activities, hasseriously lost the trust of consumers due to some heartless business operators, and the excellent
distribution function that this business format originally had has been undermined which has been
overlooked without gaining social recognition. However, it is also true that the industry has
provided a wide range of employment and work opportunities for housewives seeking
supplemental income to make up a shortfall from their income, couples who find purpose in theirwork after retirement, or individuals who are starting their own businesses with the aim of further
increasing their income. In order for society to understand this fact, it is necessary for all those
involved in this business to be law-abiding and to conduct their business with a high morality that
goes beyond the level of individual laws and regulations. Specifically, in addition to theregulations on multilevel marketing transactions, it is necessary to understood that multilevelmarketing Transactions can also be considered door-to-door sales in that transactions areconducted with individuals who do not own a store at a location other than a sales office, and thevarious laws and regulations, including those on door-to-door sales, must be complied with. In
addition, those who preside over multilevel marketing transactions must not only assume legal
responsibility as "supervisors" as defined by the ACT, but also have the mission to realize soundbusiness through education, guidance, and management of individual business members, and toenhance the social reputation of multilevel marketing transactions as a form of distribution.

The Japan Direct Selling Association (hereinafter referred to as "JDSA ") has established thefollowing guidelines for its Members (including businesses affiliated with such members; thesame applies hereinafter) toward the "ideal state" of this business form so that it will be acceptedby society and recognized as a form of business trusted by consumers and the Members pledge
to comply with these provisions.

1. Purpose
The purpose of this Guidelines is to protect the interests of consumers and others and to promote
appropriate multilevel marketing transactions by ensuring fairness in multilevel marketingtransactions and preventing damage that may be incurred by consumers who are inexperienced
in commercial transactions, which stipulates the matters that Members must comply with as"supervisors" and the matters that the business members must comply with.

2. Scope of Application
This Guideline applies to multilevel marketing transactions conducted by organizations whose
Members are supervisors, and in which the parties involved are individuals who do not own astore.

3. Details of Self-Imposed Code of Conduct
When conducting multilevel marketing transactions, laws and regulations including the Act must
be observed. In addition, the following items must be complied.

(1) Disclosure of Information
Members shall create documents to be delivered for disclosure of information a clear and easyto-read manner to facilitate the understanding of the counterparty, and shall endeavor to provide
information that is suited to the capacity to understand for the counterparty, for example, byproviding oral supplementary explanations in addition to the delivery of written documents.
In addition, when advertising or explaining the rewards that can be obtained by the counterparty
in connection with the solicitation to join such business organization, Members shall make every
effort to provide specific and easy-to-understand grounds by disclosing accurate and objective
information that will not lead the counterparty to have excessive expectations.

(2) Cautionary Statement
In order to guide the calm judgment of the counterparty of a solicitation, who are individuals anddo not own a store, the cautionary statements should be included in the document to be delivered(the statutory document for Multilevel Marketing Transactions stipulated in the Act) with thefollowing purpose which shall be indicated in red and in the area marked in red.

<Indication for Attention>
When joining the business organization, it should be clearly stated that the Members shouldmake a decision based on their own judgment after thoroughly reading the documents delivered

and objectively examining the business plan and other information.

(3) Guidance and Education for Business Members
Members, as supervisors of business organizations, shall alert their business members to thefollowing as prohibited matters, and shall take strict action against violations thereof.

1) Prohibited Acts
1. Citing rare examples of income or using exaggerated expressions to emphasize incomeShowing rare examples, such as showing a statement of monthly income of JPY1.3M, andexplaining as if such income is possible for anyone.

Explaining things like “Get rich quick” or "Make a lot of money”.

2. Encouraging people to purchase of high ticket items on the assumption that the margin will be
sufficient to settle for them.
Explaining uncertain income as if it were certain, such as "If you introduce people, you cansettle with the margin", and recommending the purchase of high ticket items.

3. Inducing people to sign a contract on the premise of lending or borrowing in the name of thecounterparty, or by misrepresenting the personal information of the person.
Inducing a young person to sign a contract in his mother's name.

Borrowing the name of a registered owner on the assumption that "I will pay for the goods".

Instructing the borrower to enter false information in the contract, except for the name, incase the credit is not approved.

4. Encouraging borrowing money.
Encouraging people to borrow money by explaining things like, “You will definitely succeed,
and the products of the company are great, so you should join even if you borrow money”.

5. Forcing people to purchase unnecessary and non-urgent items by mentioning that those are
obviously necessary for your business.
Forcing people to purchase unnecessary products, such as saying, “Purchasing a certain
amount of products is mandatory for registering the business registration'.

6. Forcing people to sign contracts without fully explaining the details of the business plan andwithout making them aware that they are signing up for a business.

Cases where there is actually no inventory for a plan that cannot be applied without
inventory, but failing to explain this fact.

Inviting friends by saying, "I will be just talking about the environment, not selling
products.

7. Concealing the purpose of inviting them for solicitation to the business

Inviting a friend to an acquaintance's home by saying, "I want to meet you" or "Invitation
to an event hosted by the company" without telling the friend that it is a solicitation for thebusiness.

8. Inducing people to join the sales organization through job advertisements without properly
announcing specific benefits or specific burdens.
Distributing flyers such as " Looking for people who want to earn income", without stating
the registration fee or remuneration, even though the flyer is an invitation to the salesorganization.

9. Sending advertisements or materials that may be perceived as advertisements by email
without the consent of the counterparty.
Stating as if the plan is an organization or business plan approved by the government orother public institutions.

10. To explain that the business is licensed by the government, contrary to the fact.

11. Soliciting aggressively and persistently in a way that makes people feel annoyed.
Persistently soliciting people to understand that the product is good despite the refusalfrom them.

2) The same applies to the "Prohibited acts for each product" separately stipulated forbusinesses run by Members.

(4) Return (Buyback) System
If a member conducts a multilevel marketing undertakings or has business members of thebusiness organization it presides conduct, in order to protect individuals who do not own a store
are inexperienced in commercial transactions, the Member shall establish a return system forpurchased products, and comply with the provisions set forth below. If a business member
withdraws from the business (e.g., withdrawal) after the cooling-off period has passed, orrequests the counterparty to the contract to return purchased (including purchases) products inwriting, the following criteria apply, it is necessary to take measures to complete the acceptanceprocess for returned goods and to complete the associated settelment promptly after the date ofreceipt of the returned goods. However, this paragraph shall not apply in cases where the rules of
mid-term cancellation or return concerning multilevel marketing contracts under the "Act on
Specified Commercial Transactions" apply.

The Member shall be jointly and severally liable with the business member who received thereturned goods for the repayment of debts arising from the return of such goods. If it is difficult toaccept the return because the business member who is to receive the return has already left thebusiness organization, the Member shall be the final person in charge of responding to therequest for return. The details of the return (buyback) system must be clearly stated to thecounterparty in the statutory document for multilevel marketing transactions stipulated by the Act.

<Scope of Business Members to whom the Return (Buyback) System applies>
Members and sole proprietors who do not own a store and join a business organization run by amember of this association or a business entity affiliated with a member obtains the qualification
to conduct the business (if there is more than one qualification, the first qualification) within one
year from the date of acquisition of the qualification.

<Scope of Items that may be returned>
All items (including those for self consumption), including promotional items and samples, must
be unused (even used items may be returned if they have been used or consumed by the sales
representative, etc.) and have been contracted for within one year from the date of the request forreturn.
However, the following items are not eligible for return.
1) Items that have been resold
2) Items that have been lost or damaged due to the own fault of the user.
The following items may be excluded from the scope of return if a prior written statement (adocument describing the relevant return policy) clearly indicates to the counterparty that such
goods are not subject to return.
1) Items whose quality guarantee period or best-before date has passed and for which 90 days
have elapsed since the date of delivery.
2) Items that are sold for a limited time only, regionally limited, or other limited sales (items not
sold in regular sales), and for which 90 days have elapsed since the date of delivery.

<Amount to be refunded>The amount to be refunded shall be the purchase price of the returned item, less a (cancellation)fee equivalent to a maximum of 10%and any commission or other specified profit alreadyreceived for the purchase of the returned item. The cost of shipping and other expenses
associated with the return shall be borne by the person requesting the return.

(5) Other matters to be observed
In addition to the above, Members shall take necessary measures with respect to the following
matters.

1) Education for Business Members
1. It is necessary to establish an appropriate education system for all parties of the affiliatedbusiness organization in accordance with the Act and other relevant laws and regulations(e.g., Consumer Contracts Act, Act on the Protection of Personal Information, Act against
Unjustifiable Premiums and Misleading Representations, Pharmaceutical and Medical DeviceAct) and this Guideline, and strive to improve their qualifications.
2. Business members shall be provided with the necessary education on legal obligations,
including permission, notification, registration, and taxes, required for the relevant multilevelmarketing business.

2) Establishment of a Complaint Handling System
1. In order to prevent problems from occurring in the business, it is necessary to make its best
efforts to prevent complaints, establish a consultation service that is easily accessible toconsumers and business members, and always respond seriously to the opinions received
and accept such complaints with a positive attitude and strive to handle complaints
appropriately and promptly.
2. Furthermore, even if the business member is an independent self-employed person, it isrequired to recognize that in multilevel marketing transactions, the supervisor must try toresolve business-related issues, and it should endeavor to establish a system for acceptanceand for directing and communicating with the supervisor for processing.
3. If a complaint regarding a Member occurs outside of Japan and it is difficult to resolve it inthat country, the Association will carry out work related to resolution as necessary. In suchcases, the Association shall cooperate with the Member to resolve the complaint.

3) Appropriate Explanations for Solicitation
When providing explanations or demonstrations regarding the sale of products or the solicitation
for participating the business, it is necessary to endeavor to provide thorough guidance tobusiness members to ensure that such explanations or demonstrations are accurate andappropriate and based on facts, and are not false or exaggerated. In addition, efforts shall bemade to instruct business members that compensation is paid based on the sales and personal
consumption of the business member and his or her downline, and remuneration cannot beearned simply by having other people join the sales system.

4) Connection of Debts and Credits due to Withdrawal of Business Member
In the event that a business Member withdraws from a business causes a severing of businesscredit and debt with uplines or downlines of the person withdrawn, measures shall be
implemented to connect such relationships so that the business member will not be unfairly
disadvantaged.

5) Solicitation to Business Members of Other Companies or Organizations
When it is commercially unethical to systematically solicit business members of other companies
or organizations, it is required to make efforts to develop sound solicitation activities so that suchactivities will not be conducted, nor will business menbers within such organizations be subjected
to such activities.

6) Solicitation of Persons considered to be inappropriate as Transaction Partners
It is necessary to that business members do not solicit anyone who is considered inappropriate
for conducting business activities, such as minors, those who have just reached the age ofmajority, students, adult wards, wards, persons under curatorship or assistance, and others.

7) Disclosure of Transaction Status Related to Business
It is required to report to business members the status of transactions (sales, purchases, incomeand expenditure details, commissions, bonuses, discounts, product shipments, cancellations, andother related data) as necessary, and make efforts to disclose information to avoid any problems,
especially with regard to payment of money.

8) Optimization of Inventory
A system of checks and controls related to the amount of inventory held by business members
shall be established in order not to be excessive, taking into account the sales capacity ofbusiness members, the competitiveness of the products and market environment, the return andrefund policy of the company, changes over time of the products, and other factors, and thatappropriate inventory is maintained.

9) Materials and Resources for Sales Promotion and Training
Materials for sales promotions or trainings provided to downlines or others (these include not onlytools, equipment, or goods such as books, magazines, and documents, but also electronic
information such as provision of paid services, downloadable programs) are created by businessmembers, efforts shall be made to ascertain how such materials and documents are used or soldat the business fields of the creators and their downlines or others with respect to the following
points.

i.

Providing only materials of equivalent standards to those observed by Members so as not toviolate relevant laws and regulations.

ii.

Not forcing other sales personnel to purchase such materials.

iii.

When selling such materials, they must be priced appropriately (i.e., not at a price that will
result in excessive profits).

iv.

A return policy equivalent to that of Members is provided.

v.

The name, address, and telephone number of the Member are printed (including in an
attachment to the instruction manual)

If the actual situation ascertained through the above is in violation of the terms andconditions stipulated by the Member or is misleading or fraudulent to the counterparty,necessary and appropriate actions, such as having the business member stop offering andselling the product, shall be promptly implemented.

10) Cases where the business member is employed in a position other than that of the businessconcerned
If a business member is employed in a position other than that of the business concerned, thebusiness member shall comply with the rules of employment (work regulations, service
regulations, and others) and be given thorough guidance so as not to interfere with the businessconcerned.

Supplementary Provisions
The date of enactment of this Guideline is March 28, 2002 (the date of the resolution of the Boardof Directors), and it shall come into effect on June 6, 2002. However, the provisions of "(4) Return(Buyback) System" shall be implemented from January 1, 2003, and until then, the provisions of"(3) Return (Buyback) System" stipulated in the "Self-Imposed Regulatory Guidelines for Door-toDoor Sales with Consumer Participation" shall apply.
The "Self-Imposed Regulatory Guidelines for Door-to-Door Sales with Consumer Participation"
shall be abolished as of the implementation date of this Guideline.

Supplementary Provisions (October 5, 2004)
The revised regulations of this Guideline shall come into effect as of the date of the resolution of
the Board of Directors (October 5, 2004).

Supplementary Provisions (March 24, 2005)
The revised regulations for this Guideline shall come into effect as of the date of the resolution of
the Board of Directors (March 24, 2005).

Supplementary Provisions (October 8, 2009)
The revised regulations for this Guideline shall come into effect as of the date of the resolution ofthe Board of Directors (October 8, 2009).

Supplementary Provisions (April 1, 2012)
The revised regulations for this Guideline shall come into effect on the day of registration of theincorporation of public interest corporations as set forth in Article 106, Paragraph 1 of the Act on
Arrangement of Relevant Acts Incidental to Enforcement of the Act on General Incorporated
Associations and General Incorporated Foundations and the Act on Authorization of Public
Interest Incorporated Associations and Public Interest Incorporated Foundation.

Supplementary Provisions (May 22, 2019)
The revised regulations for this Guideline shall come into effect as of the date of the resolution ofthe Board of Directors (May 22, 2019).

Supplementary Provision (March 16, 2022)
The revised regulations for this Guideline shall come into effect as of the date of the resolution ofthe Board of Directors (March 16, 2022).