CODEOFCONDUCT
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Isetan Mitsukoshi Group

Editing and publishing
Isetan Mitsukoshi Holdings Ltd.
General Affairs Department

Contents
Introduction

3 Contributions to society

Top message

P03

What is the Isetan Mitsukoshi Group
Code of Conduct?

P07

When you find it difficult to judge
your own actions

P09

conservation and supply chains
2 Social contribution activities

3Part
How to interact with customers

1

Part
The Group’s stance

Conduct for Customer

Corporate Stance1 High levels of compliance and ethical behavior P12
2 Handling of human rights

P13

3 How to deal with stakeholders

P14

4 Responsible business activities

P15

2

Part
Responsibility towards
society

1 Relationships with customers

P23

2 Provision of services that exceed

P24

3 Protection of personal information

P25

expectations

4

Part
Preparedness in theworkplace, fair work
environments
Conduct for Ourself

Conduct for Society

1 Equal opportunity and prohibition of

1 Fair trade

P17

2

P18

Observance of social rules

P21

1 Consideration for global environmental

1 Insider trading
2 Prohibition of bribery
3 Entertainment, gifts and donations
4 Exclusion of antisocial forces
5 Conflicts of interest and distinction between public
and private
6 Handling of records and appropriate information

P27

discrimination

1 Diversity, equity and inclusion
2 Harassment

2 Health and safety

P28

1 Health management
2 Creation of workplaces that are easy to work in
3 Growth and challenges

3 Raising problems and reporting

P29

disclosure

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Top Message
From the CEO
to allLast year, we enacted a new corporate philosophy and are aiming to be a “retail group centeredon extraordinary department
stores working toward improving
the lives of our customers” byrealizing our mission of “touching peopleʼs hearts with human-driven experiences.”
Recently, we also enacted the
new Isetan Mitsukoshi Group
Code of Conduct, which presents ethical guidelines on how
we should judge and act in orderToshiyuki Hosoya
Director, President and CEO

03

to be a trusted presence, to put
this corporate philosophy into
practice.
We have carried out business formany years under the reputationof various group companies including Mitsukoshi, Isetan, Marui
Imai and Iwataya, but our business has been established on
the trust of all stakeholders, including customers.
We have trust from society thathas been cultivated throughout
our long history and an image ofour brand, and we have a responsibility that we should fulfill
in society.
I think that we, each and every
one of us, can succeed in business and make it sustainable
only if we follow the companyʼs

corporate philosophy at all times,
most notably by choosing soundmethods with a sincere attitudeand fulfilling our social responsibilities. This is action that is fundamental in the company
groupʼs pursuit of sustainability
management.
I believe that if all group executives and employees, including
myself, understand the content
of this Code of Conduct fully anduse it in our daily actions andwhen making decisions, rather
than just looking back on it when
we are in trouble, it will connect
to the improvement of corporate
value and the growth of thegroup. Letʼs work together sothat we can become a moretrusted company.

04

From the CAO to all
Throughout its long history, theincluding social common sense

correct decision or action, or feel

Isetan Mitsukoshi Group has

and moral principles that may

that something is wrong, pleasebuilt relationships of trust with all

not be stated explicitly.

consult

stakeholders, including custom-

Are the decisions and actions

around you or your supervisor

ers, business partners, share-

you are about to take now some-right away.

holders, local communities andthing you can be truly proud of,

The trust of the Isetan Mitsukoshi

employees, by dealing with themeven to your precious family andGroup is established on the cor-sincerely.

friends? Please choose honest

rect and sincere actions of eachThis trust is an important asset

acts correctly at all times in lightand every one of you.

for us, but it can be underminedof this Isetan Mitsukoshi GroupLetʼs all work together to create

once an incident or scandal oc-

Code of Conduct.

a sound corporate culture withincurs, and our brand image canHowever, this Code of Conduct

which we can work with confi-

be damaged in an instant.

expresses the “principles” fordence and pride.

In order for Isetan Mitsukoshi

our daily activities and does not

Group to continue being a com-cover all situations.

pany whose existence is expect-

It is important that you read anded from now on too, we must

think carefully about the Code of

not only observe laws and regu-

Conduct while imagining various

lations in our daily activities, but

situations from your own stand-also act based on ethics and in-point.

tegrity as a corporate person,

And, if you are at a loss over the

Top Message
05

with

the

members

Akira Kimbara
Managing Executive Officer
CAO, CRO and CHRO

06

What is the Isetan Mitsukoshi Group Code of Conduct?

Why a Code of Conduct is required
As a member of a company group that values the assets and brand that it has
cultivated throughout its long history, and as members of a highly public and well-known
department store group, each and every one of us must advance our business activities
sincerely, with good sense, dignity and high ethical standards.
We aim for each and every officer and employee to be able to think flexibly and act

Corporatephilosophy
The most fundamental concept

correctly by reconsidering and rereading when they have doubts about their own orothersʼ actions, or are at a loss over a decision in their daily activities or work.
This Code of Conduct will be updated and improved as required based on the demandsof the times and the internal environment.

at the heart of all Isetan Mitsukoshi Group
corporate activities

Scope of application of the Code of Conduct
MissionValuesThis Code of Conduct has been enacted as an ethical guideline common throughout
the Isetan Mitsukoshi Group and applies to all officers and employees* of the Group.

VisionWe expect business partners to understand the content of this Code of Conduct andput it into practice.
* All officers, including directors, executive officers, corporate auditors and operating officers, of Isetan Mitsukoshi Group companies,
and employees, etc., with an employment relationship with Isetan Mitsukoshi Group companies

Code of Conduct

Responsibilities of officers and employees
All Group officers and employees must understand the content of this Code fully andact with integrity at all times. In addition, senior personnel are required not only tounderstand this Code and put it into practice, but to create an environment in which

This expresses the ethical standards on how executives andemployees of the Isetan Mitsukoshi Group should make decisions
and act in their daily work, and supports the corporate philosophy.

subordinates can understand this Code and talk easily when they are at a loss over adecision.
If this Code of Conduct is violated, it may damage our credibility with customers andthe market, and as a result, lead to economic losses for the company of the worseningof its reputation.
If you cause a significant loss to the company, you may be subject to disciplinary action
based on laws and regulations, internal rules, employment rules, etc.

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When you find it difficult to judge your own actions
If you are at a loss over whether or not a choice is correct or over an action, ask thefollowing questions to confirm whether the four promises are being kept.

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practice, and is the foundation of our corporate philosophy.

The Group’s stance
Responsibility towards societyPart 3

How to interact with customers

Part 4

Preparedness in the workplace,fair work environments

1Part 2Part

Part 11High levels of compliance awarenessand ethical behavior

To put the Isetan Mitsukoshi Group Corporate Philosophy into practice,
we not only observe all laws, regulations and rules andhave high awareness of compliance, but also act correctly based onhigh ethical standards, and with good sense and dignity as a corporate person.

The Group’s stance1 High levels of compliance and ethical behavior

P12

2 Handling of human rights

P13

3 How to deal with stakeholders

P14

4 Responsible business activities

P15

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We implement education to improve the understanding andWe emphasize dialogue and communication with stakeholders,awareness of all officers and employees so that our business activities,

respond to the opinions we receive sincerely,

the products and services we handle and our business relationships

and fulfill our responsibility to explain by disclosing information in

do not cause or encourage negative impacts on human rights,

a timely and appropriate manner.

Preparedness in the workplace,fair work environments

local communities and employees.

How to interact with customers

including customers, business partners, shareholders,

and take care so that we carry out business activities considerate of individual dignity.

Responsibility towards society

We act sincerely, giving full consideration to the impacts on stakeholders,

we respect the rights of the various people with whom we interact,

The Group’s stanceIn accordance with the Isetan Mitsukoshi Group Human Rights Policy,

Part 4

How to deal with stakeholders

Part 3

Handling of human rights

Part 2

3
Part 1

2

and if such impacts should occur, we will act sincerely toward its resolution.

ColumnColumnWhat scope of human rights should we pay attention to?

Stakeholder Engagement
The Isetan Mitsukoshi Group will build win-win relationships with all stakeholders in a wellbalanced manner through future-oriented and friendly dialogue and communication, thereby
contributing to the enhancement of our social value and corporate value.

Employees

Business
Partners

13

Local
Communities

Suppliers

Future-oriented
engagement

Based on mutual understanding with our stakeholders, we aim to
be a company that continues to meet the needs of the times bysolving problems.

Balancedmanagement

Emphasizing balance among stakeholders, we aim to build
relationships that earn the trust of all stakeholders.

Creating fansThrough continuous dialogue and appropriate feedback, we aim
to make all stakeholders fans of the Isetan Mitsukoshi Group.

customers

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4

Responsible business activities

We respect free and fair competition, uphold related laws and regulations andinternal rules, and maintain appropriate relationships with stakeholders.
We carry out business activities with a high level of ethics based on this Code of Conduct,
and put this Code of Conduct into practice in the competitive environment.

Part

2

Responsibility towards
society
1 Fair trade

P17

2 Observance of social rules

P18

1

Insider trading

2

Prohibition of bribery

3Entertainment, gifts and donations

4

Exclusion of antisocial forces

5

Conflicts of interest and distinction between public and private

6

Handling of records and appropriate information disclosure

3 Contributions to society

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1Consideration for global environmental conservation and supply chains

2Social contribution activities

P21

The Group’s stance
Responsibility towards society
How to interact with customers
Preparedness in the workplace,fair work environments

1

We carry out business with all business partners in accordance with related laws and regulations

Insider trading

such as the Antimonopoly Act, and internal rules, and do not engage in acts that would constituteabuse of a dominant position or a violation of the Subcontract Act.

Part 4

Observance of social rules

Part 3

Fair trade

Part 2

2
Part 1

1

We recognize that insider trading is regulated regardless of the amount involved,
and do not trade in shares or other securities, etc., while knowing material information that

We recognize the importance of free competition in the market and do not engage in unfair

has not been disclosed about the Company or Company Group, etc.

restraints of trade such as bid rigging or cartels, or unfair trade or other acts that could besuspected of constituting such conduct.

We do not communicate insider information to other people,
including family members and business associates, or engage in other suspicious activities

We conclude appropriate contracts with business partners and carry out transactions basedsuch as recommending transactions to other people.

on contracts, applicable laws and regulations, company policies and rules, etc.

ColumnThe impacts caused by insider trading
If you find out internal information about a company that could affect its stock price and buy orsell shares or bonds before the information is disclosed publicly (known as “insider trading”),
you can profit more easily than general investors who do not know that information, and trustin the securities market will be damaged. Such acts are regulated strictly by the Financial
Instruments and Exchange Act, which imposes prison sentences, fines, or both on people who
engage in insider trading, regardless of whether or not they made a profit.
If any officer or employee of the Company Group was subject to such disciplinary action, it
could lead to a loss of trust in us by the market, financial institutions, business partners andshareholders.
The shares traded in the market are shares of Isetan Mitsukoshi Holdings Ltd. The Company
Group has established Regulations for the Prevention of Insider Trading, under which
employees belonging to specific divisions who are likely to obtain knowledge of insider
information in particular are obliged to notify the Company in advance when they intend to buy
or sell shares, etc., in Isetan Mitsukoshi Holdings.

2

Prohibition of bribery
We observe laws and regulations concerning bribery, and do not provide inappropriate gifts,
entertainment or other economic benefits, including bribes, kickbacks or other illegal payments.

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Responsibility towards society
How to interact with customers
Preparedness in the workplace,fair work environments

for legitimate business purposes and manage them appropriately.

The Group’s stance

where there is a concern that it will invite the suspicion or distrust of societyPart 4We use the Companyʼs funds, assets, data and information onlyPart 3We do not request, accept or give any gift, entertainment or other economic benefit

Part 2

5

Conflicts of interest and distinction between public and private

Part 1

3Entertainment, gifts and donationsin terms of high expense or frequency, etc.
We act in the best interests of the Company at all times and do not engage in acts that
When making donations to various organizations, etc.,

conflict with the interests of the company, such as doing business with other people

we clarify their purpose and social significance, observe related laws and regulations,for our own benefit or prioritizing the interests of other companies.

and follow methods that ensure legitimacy and transparency.
If a transaction or relationship that could be expected to create a conflict ofIf we donate to or support a charitable organization related to the Companyʼs business,interest does occur, we take appropriate measures,

we do so only after conducting the necessary investigations and confirming the reasonablenesssuch as obtaining the approval required based on company rules, etc.

of the donation, etc., based on the procedures established in the Companyʼs rules.
6
4

Exclusion of antisocial forces

Handling of records and appropriate information disclosure
We disclose corporate information, including financial conditions,

We respond to antisocial forces with a resolute attitudein a timely and appropriate manner, and do not disclose inaccurate

and do not engage in any transactions with them.

or inappropriate information, or conceal information.

We have no involvement whatsoever with any act of terror,

We prepare all records and reports,

money laundering or other crimes.

including accounting books and financial records, accurately and without omission,and in a fair and timely manner, and present the facts appropriately.

ColumnAbout the Act on Prevention of Transfer of Criminal Proceeds
Financial institutions, credit card businesses, and specified business that handle jewelry, precious
metals, etc., including department stores, are obliged to confirm the identity of customers whencompleting transactions, prepare and maintain records, and submit notification of suspicioustransactions to the state.
This is aimed at preventing money laundering and the financing of terrorism by criminal organizations,ensuring the safety and peace of the daily lives of citizens, and contributing to the sound developmentof economic activities, as stipulated in the Act on Prevention of Transfer of Criminal Proceeds.
* The details of the Act on Prevention of Transfer of Criminal Proceeds are posted on the following
website of the National Police Agency.

https://www.npa.go.jp/sosikihanzai/jafic/hourei/law_com.htm

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3

Contributions to society

1Consideration for global environmental conservation and supply chains
We contribute to the realization of a sustainable society by giving consideration to
the issues of climate change, the preservation of biodiversity,
conservation of water resources, etc., in all aspects of business.
We work on the reduction of environmental impacts throughout the supply chains

Part

3

How to interact withcustomersfor our products and services, from manufacturing, distribution,
sales and the provision of services to product disposal.

2

Social contribution activities
As a member of the community and society, we deepen mutual interaction
and build relationships of trust, and collaborate to contribute to the resolution ofissues in the community and society, and to their invigoration.
As a good corporate citizen, we strive for the realization of a sustainable society bypromoting positive social contributions for the realization of affluent andlivable local and international society.

ColumnThe existence of a company is established based on
coexistence and co-prosperity with society.
To realize a “retail group centered on extraordinary department stores working toward
improving the lives of our customers,” it is essential that we put sustainability management into
practice, and “coexist and prosper” with society.
We understand the burden that our business activities have on the environment and workon protection of the environment. Let’s think about how we can contribute to social issues.

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1 Relationships with customers

P23

2 Provision of services that exceed expectations

P24

3 Protection of personal information

P25

We strive for the creation of an environment and the provision of services

To meet the needs of customers,that all customers can use with peace of mind by taking all possible precautions

we use all kinds of information at all times, and each and every one of us aims toin safety measures and quality management measures for our products

improve our expertise and provide innovative ideas.

and services from the standpoint of customers.

Preparedness in the workplace,fair work environments

and sophisticated customers, and realizing them with speed.

How to interact with customers

We provide greater satisfaction by reading the true needs of our increasingly diverse

regulations and social norms, and respond to customers with high ethical standards.

Responsibility towards society

We listen sincerely to customersʼ opinions and live up to their trust and expectations.

The Group’s stance

We recognize the public nature of our business as a “retail group centered on extraordinary
department stores working toward improving the lives of our customers” and comply with laws,

Part 4

Provision of services that exceed
expectations

Part 3

Relationships with customers

Part 2

2
Part 1

1

We meet the expectations of our customers by gathering together the strengths ofIn relationships with customers, we distinguish between our private andthe Isetan Mitsukoshi Group, which develops diverse business, and working as one.

business standpoints, and do not provide inappropriate gifts or entertainmentthat deviate from socially accepted norms.

ColumnEnsuring safety and security
To ensure customers’ safety and security, we are required to observe laws and regulations,and maintain a safe and secure shopping environment, including “product quality
management”,“proper and fair labeling”, “upholding promises and contracts with customers”,
and “handling customers’ personal information with care”.

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3

Protection of personal information

We pay close attention to the management of personal information received
from customers and manage it strictly.
We use and provide information only if necessary for business andwithin the scope of business purposes, and protect customer privacy.

Part

4

Preparedness in theworkplace, fair work
environments
1 Equal opportunity and prohibition of discrimination

Column1

Diversity, equity and inclusion

2

Harassment

2 Health and safety

What is personal information?

1

Health management

Personal information means information about an individual that can be used to identify

2

Creation of workplaces that are easy to work in

the individual, either by this information alone or in combination with other information, and3

Growth and challenges

P29

P30

information that includes personal identification codes (e.g.: driver’s license number, insurance
reference number, etc.).
Specific examples

Name, date of birth, address, telephone number, e-mail address,
card number, family composition, occupation, purchasing history, etc.

The Act on the Protection of Personal Information requires business operators to ensure theappropriate handling of personal information while taking into consideration its usefulness.
Caution is required because if this act is violated, it can lead to penalties and the decline ofsocial credibility.
For details, please refer to Isetan Mitsukoshi Group’s “Personal Information Handling Rules”
and “the Isetan Mitsukoshi Personal Information Handling Rulebook”.

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3 Raising problems and reporting

P31

the safety of officers and employees is the number one priority,and lively corporate culture and environment within which diverse human resources

through the correct recording of work hours, etc.

can demonstrate their respective abilities to the maximum.
We aim for the creation of an environment within which each andWe work on the realization of a fair society in which each andevery individual can continue to work safely while improving their physical andevery individual can use their talents, share their wisdom and play an active rolemental health, motivation and vitality.

Preparedness in the workplace,fair work environments

We strive for the provision and maintenance of a work environment in which

each and every Group officer and employee, and promote the creation of a free

How to interact with customers

We respect the diverse personalities, backgrounds, ways of thinking and values of

Responsibility towards society

1

Health management

The Group’s stance1

Diversity, equity and inclusion

Part 4

Health and safety

Part 3Equal opportunity and prohibitionof discrimination

Part 2

2
Part 1

1while cooperating with all kinds of people.
We carry out transfers, promotions, evaluations and treatment based on

2fair and equitable standards without discrimination.

Creation of workplaces that are easy to work in
We ensure the soundness of employment and labor at all times in compliance with theapplicable laws and regulations of each country where we carry out business activities.

2

Harassment
We have contact with all people with dignity and respect, and do not engage inor tolerate harassment of any kind, including harassment from outside the company.

We aim for the creation of a sound and open-minded work environment within
which workplace colleagues make contact with sincerity, help each other,respect each other and co-create regardless of position.

We do not tolerate bullying or harassment within the company.
We understand correctly what we must not do or say,3

continue to update our correct knowledge and high awareness of harassment,

Growth and challenges

and face up to zero harassment proactively.

We continue new initiatives, sensing the future beyond the movements of
the world and changes in the environment. In addition, we support andvalue employees who take on challenges positively.
We work on business reform and promote dialogue at all times.

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Columncooperate with the investigation of a matter.

Preparedness in the workplace,fair work environments

and we do not tolerate any acts of retaliation against people who

How to interact with customers

We treat people who make reports sincerely fairly and respectfully,

Responsibility towards society

we do so positively.

The Group’s stance

If we are required to cooperate for an investigation,

Part 4

with courage, without turning a blind eye.

Part 3

If we discover an act, etc., that may violate the law, regulations or
this Code of Conduct, we report and consult with related departments promptly

Joint Declaration by Labor and Management Committing
to the Creation of a Workplace Environment Where
People Can Work with Peace of Mind

Part 2

Raising problems and reporting

Part 1

3

We shall comply with working hour management rules
and work to reform our operations.
We shall ensure that working hours are properly recorded.
We shall not imprint or entertimes other than the start andend of our workday, nor shallwe make unauthorizedalterations to records.

Individuals

We shall ensure that subordinates
are recording their working hours
Supervisors properly, and instruct and guidethem to make corrections
as necessary.

We shall all work to reform our operations.
We shall uncover the seeds ofoperational reforms one by one,and solve them as a team.

Individuals

Supervisors

We shall make and implement
decisions to stop, consolidate,and eliminate bias in our business
operations.

We shall undertake our work through dialogue.
We shall share and discuss ourwork progress and issues with
our supervisor and team.

Individuals

We shall create time for dialogue
and a climate for dialogue in order toSupervisors fully understand the issues faced byour subordinates and teams.

We shall never engage in or tolerate any form of harassment.
We shall value both the people we work with and ourselves.
We shall create a workplace with a sense of equality and trust where everyone accepts thediffering opinions of others and can honestly express their own feelings.
We shall keep updating ourselves with the correct knowledge and a high level of awareness.
We shall strive to correctly understand what not to do and what not to say,and proactively work toward zero harassment.
We shall never turn a blind eye.
If we suspect someone is being harassed, we shall not overlook the situation, but shall havethe courage to speak up or talk to someone about it. The company shall respond tosuch consultations and reports in good faith and deal with harassment in a strict manner.

Toshiyuki Hosoya
Director, President and CEO,
Isetan Mitsukoshi Holdings Ltd.

29

Fumikazu Kikuchi
President of the Headquarters Executive Committee,
Isetan Mitsukoshi Group Labor Union30