DeNA Group Policy for the Prevention of Bribery & Corruption
Established April 1, 2024

DeNA Co., Ltd. (hereinafter referred to as “DeNA”) and all its subsidiaries (collectively with DeNA,the“DeNA Group”) in the DeNA Code of Conduct establish the principle that in our business activities
we shall comply with laws and regulations concerning the prohibition of bribes. We shall under nocircumstances engage in any conduct that could be considered bribery, corruption, or offering ofbenefits for preferential treatment to domestic or foreign public officials, and we shall always follow
social common sense and sound business practices, and we shall not engage in any conduct that
could be considered a commercial bribe or accept private benefits from business partners.
Based on the above, the DeNA Group Policy for the Prevention of Bribery & Corruption (hereinafterreferred to as the "Policy") was established to prevent bribery and corruption by establishing arelevant system and rules to be complied with by the DeNA Group, and the Policy was adopted
through a board of directors resolution. This Policy applies to all officers and employees of the DeNAGroup.
We sincerely appreciate the understanding and cooperation of our business partners with the intent
and content of this Policy so that the DeNA Group can achieve our initiatives to prevent bribery andcorruption.

1. Compliance with Laws & Regulations, etc.
The DeNA Group shall comply with the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act
2010, the Commercial Bribery Regulations of the PRC, the Unfair Competition Prevention Act ofJapan, and other applicable laws and regulations against bribery and corruption in each country andregion, as well as internal rules such as this Policy, and rules and guidelines against bribery andcorruption (collectively, the "Anti-Bribery Rules").
2. Prohibition of Bribery & Corruption
The DeNA Group shall not offer or accept, directly or indirectly, any bribe or other benefit to any
person for the purpose of obtaining or maintaining business or other improper advantage.
Bribes and other benefits include, but are not limited to, entertainment, gifts, invitations, donations,political funds, etc., in addition to money.
3. Entertainment & Gifts, etc.
With respect to entertainment, gifts, invitations, donations, and political fund contributions, etc. topublic officials and/or similar persons, etc., the DeNA Group shall comply with applicable relevantlaws and regulations and follow proper procedures in accordance with the Anti-Bribery Rules.
In addition, the DeNA Group prohibits facilitation payments (small payments made solely for thepurpose of facilitating procedures in connection with ordinary administrative services). However, thisexcludes cases where there is a risk of endangering the safety of officers and employees.
With respect to entertainment, gifts, invitations, donations, and political fund contributions, etc. topersons other than public officials and similar persons, etc., the DeNA Group shall comply withapplicable relevant laws and regulations and follow proper procedures in accordance with the AntiBribery Rules.

4. Appointment of Agents, etc.
The DeNA Group shall follow the appropriate prior approval procedures, etc., in accordance with therelevant internal rules when appointing third parties such as agencies, agents, consultants, etc., whoprovide services such as providing information or mediating, representing, or facilitating transactions
for the DeNA Group (hereinafter referred to as "Agents, etc."), and shall not engage in bribery andcorruption through or using Agents, etc.
5. Handling Throughout Process Before & After M&A
When investing in or acquiring a third party, DeNA Group shall conduct due diligence on thecompany to be invested in or acquired in advance from the perspective of bribery and corruption
risk, and shall take appropriate measures from an anti-bribery and corruption perspective if it
becomes aware of bribery and/or corruption before the investment or acquisition takes place. For
merged or acquired companies, the DeNA Group will appropriately manage the anti-bribery andcorruption system to ensure that it is promptly put in place.
6. Thorough Recordkeeping & Storage
The DeNA Group shall accurately and appropriately record all transactions in its accounting books,etc., and store related documents in accordance with relevant internal regulations.
7. Monitoring & Audits
The DeNA Group regularly monitors and conducts internal audits according to the degree of bribery
and corruption risk.
8. Training
The DeNA Group will regularly provide our officers and employees with the education and training
necessary to prevent bribery and corruption, and review them as necessary to ensure compliancewith this Policy and the Anti-Bribery Rules.
9. Structure
The DeNA Group has established a whistleblowing hotline for reporting violations or potential
violations of laws and regulations. Whistleblowers may report anonymously and will not be treatedunfairly because of their reporting.
Appropriate action will be taken against violations of laws and regulations, this Policy, and the AntiBribery Rules, including correction of the violation, punishment of the perpetrator, and introductionof measures to prevent recurrence of such violations.
Updates and revisions of this Policy and the Anti-Bribery Rules will be made as necessary.

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