MARUI GROUP
Corporate Governance Guidelines

Contents
Chapter 1 General Provisions
Article 1 Purpose [2.1, 3.1 i), 3.1 ii), 4.1]
Article 2 Code of Conduct [General Principle 2, 2.2, 2.2.1, 2.3, 2.3.1, 2.4, 2.4.1]
Article 3 Sustainability Initiatives [General Principle 2, 2.3, 2.3.1, 3.1.3, 4.2.2]

Chapter 2 Corporate Governance Systems
Article 4 Organizational Structure [4.10, 4.10.1]
Article 5 Duties of Directors [2.4, 2.4.1, General Principle 3, 3.1, 3.1.3, General Principle 4, 4.1, 4.1.1, 4.1.2, 4.1.3,
4.2.2, 4.11.1, 4.13, 4.13.3, 5.2, 5.2.1]
Article 6 Composition of the Board of Directors [4.6, 4.8, 4.11, 4.11.1, 4.12]
Article 7 Proceedings of the Board of Directors [4.12.1, 4.13, 4.13.3]
Article 8 Evaluation of the Board of Directors [4.11, 4.11.3]
Article 9 Duties of Audit & Supervisory Board Members [3.2, 3.2.1, 4.13, 4.13.3, 4.4, 4.4.1]
Article 10 Composition of the Audit & Supervisory Board [4.11]
Article 11 Nominating and Compensation Committee [3.1 iii), 3.1 iv), 4.3, 4.3.1, 4.10, 4.10.1, 4.11.1]
Article 12 Sustainability Committee
Article 13 Strategy Committee
Article 14 Human Resource Strategy Committee
Article 15 Management Committee
Article 16 Directors [4.4.1, 4.5, 4.7, 4.8.1, 4.8.2, 4.11.2, 4.12, 4.13, 4.13.1, 4.13.2, 4.13.3]
Article 17 Audit & Supervisory Board Members [4.4, 4.5, 4.11.2, 4.13, 4.13.1, 4.13.2]
Article 18 Executive Officers [2.4]
Article 19 Selection of Candidates for Positions as Directors, Audit & Supervisory Board Members,
and Managers Ranked Lower Than President and Representative Director, and Dismissal of Individuals
in These Positions [3.1 iv), 3.1 v), 4.3.1, 4.3.2, 4.3.3, 4.9, 4.11, 4.11.1, 4.11.3]
Article 20 Compensation of Directors, Audit & Supervisory Board Members, and Executive Officers[3.1 iii), 4.2, 4.2.1]
Article 21 Training Policies [4.14, 4.14.1, 4.14.2]
Article 22 Independent Auditing Firm [3.2, 3.2.1, 3.2.2]
Article 23 Risk Management System [4.3, 4.3.4]

Chapter 3 Relationship with Shareholders
Article 24 Protection of Shareholder Rights [General Principle 1, 1.1, 1.1.3]
Article 25 Communication with Shareholders [General Principle 5, 5.1, 5.1.1, 5.1.2, 5.1.3]
Article 26 Ordinary General Meeting of Shareholders [1-1.1, 1.1.3, 1.2, 1.2.2, 1.2.3, 1.2.4, 1.2.5, 3.1.2]
Article 27 Basic Policies for Capital Measures [1.3, 1.6, 5.2]
Article 28 Shareholder Returns [1.3]Article 29 Cross-Shareholdings [1.4, 1.4.1, 1.4.2]
Article 30 Related Party Transactions [1.7, 4.3]

Chapter 4 Others
Article 31 Information Disclosure [1.2.1, General Principle 3, 3.1.1, 3.1.2, 4.3, 5.2]
Article 32 Internal Reporting System [2.5, 2.5.1]
Article 33 Changes to the Guidelines
Supplementary Material 1: Criteria for Independence of External Directors and Audit & Supervisory Board
Members [4.9]Supplementary Material 2: MARUI Group Policies
Note: The figures in brackets [ ] refer to the corresponding section of Japan’s Corporate Governance Code.

MARUI GROUP Corporate Governance Guidelines (Draft)
Chapter 1 General Provisions
Article 1 (Purpose)
2.1, 3.1 i),
3.1 ii), 4.1
The mission of MARUI GROUP CO., LTD., based on its corporate philosophy, is to co-create aflourishing and inclusive society that offers happiness to all together with stakeholders. MARUIGROUP aims to promote harmony and the expansion of the intersection between the interests andhappiness of six groups of stakeholders, namely customers, investors, communities and society,business partners, employees, and future generations. Moreover, the Company practices co-creation
sustainability management, which entails creating shared value through action based on theperspectives of all stakeholders and thereby improving corporate value. Accordingly, the Company
positions strengthening corporate governance among its top management priorities and has
established this document and the guidelines contained within for the purpose of promoting
management that is sound, highly transparent, and capable of efficiently generating profits. These
guidelines will be continually reexamined and refined to promote the ongoing improvement of theCompany’s corporate governance systems.

Corporate Philosophy
Continue evolving to better aid our customers
Equate the development of our people with the development of our company

Article 2 (Code of Conduct)
General Principle 2, 2.2, 2.2.1,
2.3, 2.3.1, 2.4, 2.4.1
In order to accomplish the objectives described in the previous article, the Company has establishedthe following MARUI Group Code of Conduct. All directors, Audit & Supervisory Board members,
executive officers, and employees are expected to recognize the important part they play inupholding this code, to exercise the responsibility their roles entail, and to spread awarenessregarding this code throughout the organization. The Board of Directors is tasked with actively
promoting the entrenchment and exercise of the code of conduct. Changes to the code of conduct are
only to be instituted after sufficient discussion among the Board of Directors.

MARUI Group Code of Conduct
MARUI GROUP envisions a world in which we have transcended all dichotomies to build aflourishing and inclusive society that offers happiness to all. Realizing this vision will requirethat we engage in co-creation with MARUI GROUP employees as well as with customers,
investors, communities and society, business partners, and future generations. MARUI GROUP
views every one of its stakeholders as a partner for co-creating a happier future.
The happiness to which we seek to contribute can only be realized through co-creation
with all of these stakeholders. It is based on this belief that we promote compliance with laws
and regulations as well as international rules and the principles embodied in these norms andthat we have established and adhere to the MARUI GROUP Code of Conduct.

1. Customers
Customers are the point of departure for all of our business activities. Acting in accordance withthe corporate philosophy of “continue evolving to better aid our customers,” we will strive tocreate safe and secure products, services, and stores that bring joy to all through co-creation
with customers.
2. Investors
We will pursue ongoing growth and medium-to-long-term improvements in corporate value andincrease engagement with shareholders and other investors in order to live up to the expectationsof these stakeholders. In addition, we will disclose information in a timely and appropriatemanner, conduct highly transparent business activities, and prevent insider trading.
3. Communities and Society
MARUI GROUP’s business activities connect us to various areas of communities and thegreater society. By seeking to resolve social and community issues and invigorate communities
and the greater society through our business activities, we will build trust-based relationships
with communities and society.
4. Business Partners
MARUI GROUP’s business activities are supported by co-creation activities with business
partners in Japan and overseas. By fostering trusting relationships with partners through fair andimpartial transactions, we will deepen our ties with business partners as we progress together
and promote mutual prosperity.

5. Employees
It is employees possessing a propensity for innovation founded on a capacity for empathy who
are able to contribute to the resolution of social issues through business activities. In addition toproviding employees with a safe and hygienic workplace environment, we will foster a
corporate culture that is respectful of diverse values and in which all employees can feelenergized and can continue growing.
6. Future Generations
MARUI GROUP views children and the people of the future, whom we refer to as “future
generations,” as one group of stakeholders. We seek to create value for the future together with
future generations in our quest to help build a sustainable society and global environment
through our business and in all of our other activities.
7. Environmental Preservation
Working to help build a sustainable society and global environment through our business
represents our ethical responsibility toward future generations. MARUI GROUP is thus
advancing green businesses that provide sustainable options for coexistence with the global
environment in order to transcend the dichotomy between environmental preservation andbusiness profits.
8. Respect for Human Rights
MARUI GROUP endorses international standards regarding human rights and respects the
personalities and individuality of all people. We stand in opposition of all discrimination,
whether on the basis of race, nationality, religion, ideology, belief, biological sex, age, physicalcharacteristic, gender identity, or sexual orientation.
9. Fair and Transparent Transactions
MARUI GROUP adheres to domestic and overseas ethical standards and legal regulations aswell as to its own internal rules as it promotes fair and transparent transactions while preventing
corrupt and otherwise inappropriate activities (bribery, money laundering, inappropriate
kickbacks, conflicts of interest, lobbying activities, political contributions, etc.).
10. Elimination of Antisocial Forces
We will staunchly refuse to have any connection with antisocial forces that threaten the orderand safety of society.

11. Protection and Management of Information Assets
MARUI GROUP’s business activities entail the utilization of personal information, confidential
information, and intellectual properties. These information assets are protected and managed
based on internal regulations and policies for specific asset types, and we seek to avoid
infringing on the intellectual property rights of others.
Scope of Application and Implementation
・The MARUI GROUP Code of Conduct is applicable to all Group officers and employees. Aninternal notification system is in place to quickly uncover and address activities that violate thiscode of conduct or activities that are illegal, unfair, or otherwise inappropriate.
・Moreover, the Board of Directors is expected to actively promote the entrenchment andexercise of the code of conduct and to review the code as necessary and implement revisions
when deemed prudent through sufficient discussion. Should a serious violation of the MARUIGROUP Code of Conduct occur, we will take steps to identify the cause of the violation andprevent its recurrence.
・Based on the MARUI GROUP Code of Conduct, several policies have been established todelineate in detail the Company’s stance regarding action policies, co-creation withstakeholders, and important corporate governance issues (see Supplementary Material 2).

Chapter 2 Corporate Governance Systems
Article 3 (Sustainability Initiatives)

General Principle 2, 2.3, 2.3.1, 3.1.3, 4.2.2

MARUI GROUP practices co-creation sustainability management—a forward-looking management
approach that merges business, environmental, social issue response, and governance initiatives in an
integrated manner—to contribute to the resolution of social issues and to the accomplishment of theUnited Nations Sustainable Development Goals through its business activities. To facilitate its
promotion of co-creation sustainability management, MARUI GROUP has put forth its long-term
vision of “harnessing the power of business to build a world that transcends dichotomies.” Basic
policies and priority measures have been established in accordance with this vision, and the status ofrelated initiatives is disclosed in a timely and appropriate manner.
Article 4 (Organizational Structure)
4.10, 4.10.1
The Company has selected the Company with Board of Company Auditors structure described in the
Companies Act of Japan as its organizational structure. In addition to the Board of Directors and the
Audit & Supervisory Board, the Company has also established the Nominating and Compensation
Committee, which serves as an advisory body regarding the nomination of candidates for positions
as directors or executive officers bearing special titles and is also responsible for deciding thecompensation of directors and executive officers; the Sustainability Committee, an advisory body
regarding co-creation sustainability management; the Strategy Committee, an advisory bodypertaining to business strategies; and the Management Committee, which functions as the highest
decision-making body on the operational execution level. Furthermore, the executive officer systemshall be employed to separate management decision-making, supervisory, and operational executionfunctions and to realize more-flexible operational execution.
Article 5 (Duties of Directors)
2.4, 2.4.1, General Principle 3, 3.1, 3.1.3, General Principle 4, 4.1, 4.1.1, 4.1.2, 4.1.3, 4.2.2, 4.11.1,
4.13, 4.13.3, 5.2, 5.2.1
The Board of Directors is to work toward sustainable improvements in corporate value. To this end,
it shall exert its supervisory function by realizing highly effective corporate governance andappropriately exercise its authority by making the most ideal decisions based on impartial judgment.
The Board of Directors shall make important management decisions and supervise
operational execution in accordance with relevant laws, the articles of incorporation, and internal
regulations.
The Board of Directors shall formulate management strategies and plans based on thecorporate philosophy and an accurate understanding of the Company’s capital costs (shareholders’equity costs and weighted average cost of capital) and disclose related information. The progress ofthese management strategies and plans is to be confirmed and analyzed annually. When deemednecessary, revisions shall be instituted with regard to areas such as business structures or plans forallocating management resources to new business investments, capital investments, or investments inhuman resource development, and these matters shall be disclosed.
The Board of Directors shall be involved in the formulation and implementation ofprograms for discovering and cultivating future leaders to fill senior management positions such aspresident and representative director as one facet of developing succession plans for the president
and representative director. Based on the corporate philosophy and management strategies, the Boardof Directors shall oversee the content of such programs as well as plans for future cultivation ofparticipation through assignments and promotions after completion of the program.
The Board of Directors shall disclose information regarding policies for human resource andworkplace development aimed at promoting diversity along with information on the implementation
status of these policies.
In addition, policies for ensuring diversity in promotion of mid-rank employees shall be
formulated by the Board of Directors together with voluntary, measurable targets in this regard.
Timely and appropriate disclosure will be practiced in relation to progress toward these targets.
The skills required by the Board of Directors shall be identified, and the skills of directors
shall be accrued in a manner that coincides with the characteristics of the operating environment andthe Company’s businesses. This information will be disclosed in an appropriate and timely manner.
Direct reports are to be submitted to internal auditing divisions by the Board of Directors
and effective coordination shall be practiced between these organizations.
For operational execution decisions not requiring the judgment of the Board of Directors
based on relevant laws, the articles of incorporation, and internal regulations, the Board of Directors
shall delegate decision-making authority to the Management Committee and executive officers.
The Company shall take steps to ensure that the rate of attendance by directors and Audit &Supervisory Board members at meetings of the Board of Directors is over 80%.
Article 6 (Composition of the Board of Directors)
4.6, 4.8, 4.11, 4.11.1, 4.12
The Board of Directors is to be composed of directors with a diverse range of specialties, experience,and skills and of various genders, nationalities, careers, and ages. Based on the number of directors
pursuant to the articles of incorporation, an optimal number of directors is to be maintained to ensurethat the Board of Directors is able to function with the highest possible level of effectiveness andefficiency from the following perspectives.
1. Securing a level of diversity necessary to guarantee appropriate management decision making
and supervision
2. Facilitating lively discussions at meetings of the Board of Directors centered on external
directors that have been designated as independent directors, as stipulated by the Tokyo StockExchange
In principle, one-third of directors should be external directors (independent directors). In order toincorporate a wealth of outside experience and specialized insight into management, strengthensupervisory functions of the Board of Directors, and improve the transparency of management,
MARUI GROUP will seek to include individuals with management experience at other companies
among external directors.
Article 7 (Proceedings of the Board of Directors)
4.12.1, 4.13, 4.13.3
The number of agenda items, deliberation times, and the frequency of meetings of the Board of
Directors are to be set in a manner that ensures that discussions may be conducted to a sufficientdegree.
In principle, materials related to agenda items for meetings of the Board of Directors are to
be distributed ahead of time to provide attendees with sufficient time to prepare in order to promote
lively discussions at meetings.
Yearly schedules and projected agenda items for the Board of Directors are to be decided
ahead of time to the greatest degree possible.
The Corporate Planning Division is to function as the secretariat for the Board of Directors
and shall coordinate with the relevant divisions to provide directors and Audit & Supervisory Board
members with the information necessary to perform their duties.
Article 8 (Evaluation of the Board of Directors)
4.11, 4.11.3
In order to improve the functionality of the Board of Directors, the Board’s effectiveness is to beanalyzed and evaluated once a year, in principle, and the findings of this evaluation are to bedisclosed.
Article 9 (Duties of Audit & Supervisory Board Members)
3.2, 3.2.1, 4.13, 4.13.3, 4.4, 4.4.1
The Audit & Supervisory Board is to perform audits of the operational execution of directors andexecutive officers as well as of the Company’s internal control systems and accounting procedures asan organization that is separate from management.
The Audit & Supervisory Board shall formulate standards for appropriately evaluating theindependent auditing firm. Based on these standards, the Audit & Supervisory Board is to evaluate
the degree of independence and specialized capabilities of the independent auditing firm once a year.
Using the findings of this evaluation, the Audit & Supervisory Board will be responsible for deciding
the details of proposals for the appointment or dismissal of the independent auditing firm to besubmitted at the ordinary general meeting of shareholders.
The Audit & Supervisory Board is to coordinate with external directors to ensure that they
can smoothly collect information from a sufficiently independent standpoint.

The Audit & Supervisory Board will coordinate with finance, internal auditing, and otherrelevant entities to collect a sufficient amount of necessary information for performing its duties.
Direct reports are to be submitted to internal auditing divisions by the Audit & Supervisory
Board and effective coordination shall be practiced between these organizations.
The Audit & Supervisory Board shall make decisions from an independent and objective
perspective when performing its roles and obligations, which include auditing the operational
execution of the Board of Directors and exercising authority for the appointment and dismissal of
Audit & Supervisory Board members and the accounting auditor as well as for the compensation of
Audit & Supervisory Board members.
Article 10 (Composition of the Audit & Supervisory Board)

4.11

Based on the number of Audit & Supervisory Board members pursuant to the articles ofincorporation, the Audit & Supervisory Board is to be composed of a majority of external Audit &Supervisory Board members. Audit & Supervisory Board members to be appointed shall possess theprerequisite experience and skills and have insight with regard to areas such as finance, accounting,and legal affairs. At least one Audit & Supervisory Board member shall possess specialties related tofinance and accounting.
Article 11 (Nominating and Compensation Committee)

3.1 iii), 3.1 iv), 4.3, 4.3.1, 4.10,
4.10.1, 4.11.1
The Nominating and Compensation Committee will be put in place to improve the transparency andobjectivity of the deliberation process related to the nomination of directors and executive officers
bearing special titles and to compensation systems for directors and executive officers.
The Nominating and Compensation Committee is to consist of at least three members, two
or more of whom should, in principle, be external directors.
Members of the Nominating and Compensation Committee are to be appointed throughresolution by the Board of Directors.
The Nominating and Compensation Committee shall discuss the following mattersregarding the nomination of directors and executive officers based on consultations by the Board of
Directors.
1. Matters related to the selection of director candidates to be presented at the ordinary general
meeting of shareholders
2. Matters related to the selection of executive officers bearing special titles
3. Other matters for which the Board of Directors may seek counsel
The Nominating and Compensation Committee shall be delegated authority from the Boardof Directors to discuss the following matters and make decisions regarding the compensation paid to
directors and executive officers, with compensation of directors being contained within the confinesof the compensation systems and limits approved at the ordinary general meeting of shareholders.

1. Matters related to the compensation of individual directors and titled executive officers
2. Matters related to changes in compensation systems for directors and executive officers
3. Other matters for which the Board of Directors may seek counsel or delegate authority
Article 12 (Sustainability Committee)
The Sustainability Committee shall be formed to serve as an advisory body to the Board of Directors
for the purpose of promoting co-creation sustainability management.
The Sustainability Committee shall be tasked with examining sustainability strategies andinitiatives for the entire Group and providing reports and advice to the Board of Directors on thesematters.
Members of the Sustainability Committee will comprise directors and executive officers
selected by the Board of Directors and other individuals deemed appropriate to serve as members by
the Board of Directors based on the goals of the committee.
The ESG and Disclosure Subcommittee shall be positioned as a part of the Sustainability
Committee as an organization for carrying out duties pertaining to the management of relevant risks
and other matters based on the instructions of the Board.
Article 13 (Strategy Committee)
The Strategy Committee shall be maintained as an advisory body to the Board of Directors for the
purpose of discussing and providing advice regarding Groupwide and business-specific strategic
issues to contribute to ongoing improvements to corporate value.
The Strategy Committee shall be tasked with examining strategies and initiatives for theentire Group and for individual businesses and providing reports and advice to the Board of
Directors on these matters.
Members of the Strategy Committee will comprise directors and executive officers selectedby the Board of Directors and other individuals deemed appropriate to serve as members by the
Board of Directors based on the goals of the committee.
Article 14 (Human Resource Strategy Committee)
The Human Resource Strategy Committee shall be maintained as an advisory body to the Board of
Directors for the purpose of discussing and providing advice regarding Groupwide human resource
strategy-related issues to contribute to ongoing improvements to corporate value.
The Human Resource Strategy Committee shall be tasked with examining human resource
strategies and initiatives linked to management strategies and providing reports and advice to theBoard of Directors on these matters.
Members of the Human Resource Strategy Committee will comprise directors and executive
officers selected by the Board of Directors and other individuals deemed appropriate to serve as
members by the Board of Directors based on the goals of the committee.

Article 15 (Management Committee)
The Management Committee shall exist as an organization tasked with expediting decision making
related to operational execution that comprises executive officers appointed by the Board of
Directors. This committee will be responsible for making important decisions related to operational
execution within the scope of authority delegated from the Board of Directors.
Article 16 (Directors)
4.4.1, 4.5, 4.7, 4.8.1, 4.8.2, 4.11.2, 4.12, 4.13, 4.13.1, 4.13.2, 4.13.3
The term of directors is to be set at one year, and directors are to be appointed at the ordinary general
meeting of shareholders held each year.
Directors are expected to recognize their fiduciary responsibility, based on which they are toparticipate in making important decisions as members of the Board of Directors and oversee
operational execution.
Directors shall actively provide input at meetings of the Board of Directors to facilitate
constructive discussions.
Directors are to collect the information necessary to properly play their role and performtheir duties while also diligently studying to acquire the required knowledge and insight. In
collecting information, directors may receive input from lawyers, accountants, and other specialists
as necessary.
Directors are not to allow concurrent positions as officers at other companies to interferewith the performance of their duties at the Company, and all major concurrent positions are to bedisclosed each year.
External directors (independent directors) are expected to utilize their experience and insightto supervise management, provide advice to management, and prevent conflicts of interest based on
an independent standpoint. In addition, they are to help incorporate the opinions of stakeholders into
the proceedings of the Board of Directors.
Information necessary for the external directors (independent directors) to perform theirduties is to be provided promptly through the Corporate Planning Division.
Meetings between external directors (independent directors) and Audit & Supervisory Board
members are to be held periodically to exchange information and foster a shared understanding ofissues with the aim of strengthening the supervisory function for management.
Article 17 (Audit & Supervisory Board Members)
4.4, 4.5, 4.11.2, 4.13, 4.13.1, 4.13.2
The term of Audit & Supervisory Board members is to be set at four years, and Audit & Supervisory
Board members are to be appointed at the ordinary general meeting of shareholders.
Audit & Supervisory Board members are expected to recognize their fiduciary responsibility,
based on which they are to attend meetings of the Board of Directors and other important meetings,
providing input from an objective standpoint when necessary.

Audit & Supervisory Board members are to collect the information necessary to properly
play their role and perform their duties while also diligently studying to acquire the required
knowledge and insight. In collecting information, Audit & Supervisory Board members may receive
input from lawyers, accountants, and other outside specialists as necessary.
Based on requests from Audit & Supervisory Board members, support staff are to be
assigned that possess the expertise and skills necessary for performing their duties.
Audit & Supervisory Board members are not to allow concurrent positions as officers atother companies to interfere with the performance of their duties at the Company, and all major
concurrent positions are to be disclosed each year.
Article 18 (Executive Officers)

2.4

The term of executive officers is to be set at one year, and executive officers are to be appointed by
the Board of Directors.
Executive officers are to participate in making important management decisions as membersof the Management Committee and are expected to conduct operational execution with regard to theduties delegated by the Board of Directors from the perspective of Groupwide optimization.
Executive officers are to collect the information necessary to properly play their role andperform their duties while also diligently studying to acquire the required knowledge and insight. In
collecting information, executive officers may receive input from lawyers, accountants, and otheroutside specialists as necessary.
The Company is to select executive officers from various backgrounds with differing
specialized insights and experience to promote the diversification of management.
Article 19 (Selection of Candidates for Positions as Directors, Audit & Supervisory Board
Members, and Managers Ranked Lower Than President and Representative Director, andDismissal of Individuals in These Positions)
3.1 iv), 3.1 v), 4.3.1, 4.3.2,
4.3.3, 4.9, 4.11, 4.11.1, 4.11.3
The Board of Directors shall flexibly make decisions regarding the selection of candidates for
positions as directors, Audit & Supervisory Board members, and managers ranked lower thanpresident and representative director, and the dismissal of individuals in these positions based ontransparent and impartial discussions by the Nominating and Compensation Committee members,
who comprise a majority of external directors, and on the performance of the Company.
Directors, Audit & Supervisory Board members, and managers ranked lower than president
and representative director are to be selected regardless of gender, age, or nationality, with selection
decisions based on consideration of the personalities and views of potential candidates. In thismanner, the Company shall select candidates that are capable of fulfilling the duties andresponsibilities of their positions. Candidates for positions as directors and managers ranked lower
than president and representative director shall be selected based on their potential to contribute tomedium-to-long-term improvements in the corporate value of the Company. Audit & Supervisory
Board member candidates shall be selected based on their potential to contribute to the establishmentof an impartial system for supervising the Company’s management. Candidates for positions as
external directors and external Audit & Supervisory Board members should fulfill the requirements
set forth by the Companies Act of Japan as well as the Company’s own Criteria for Independence ofExternal Directors and Audit & Supervisory Board Members (provided separately). The rationale forselecting candidates for any of these positions shall be disclosed in notices of convocation ofordinary general meetings of shareholders.
Candidates for positions as internal directors and internal Audit & Supervisory Board
members are to be recommended by directors based on personal and human resource evaluations by
the Nominating and Compensation Committee. Recommended candidates are only to be selected
after discussion by the Management Committee and the Board of Directors. Candidates for positions
as external directors and external Audit & Supervisory Board members are to be chosen for having
the necessary insight, skills, and experience required by the Company’s Board of Directors, andselection decisions are only to be made after discussion by the Management Committee and theBoard of Directors. Prior to the selection of director candidates, the candidates must be discussed by
the Nominating and Compensation Committee. Audit & Supervisory Board member candidates must
be approved by the Audit & Supervisory Board.
Article 20 (Compensation of Directors, Audit & Supervisory Board Members, and Executive
Officers)
3.1 iii), 4.2, 4.2.1
In accordance with the authority delegated from the Board of Directors, the amount of compensation
paid to individual directors is to be decided by the Nominating and Compensation Committee basedon the relevant compensation systems and set within the limit approved at the ordinary general
meeting of shareholders. These amounts are to be determined based on a comprehensive evaluationof factors including the responsibility of each director for the management of the Group and theprogress of the Group’s medium-term management plan. The amount of compensation paid toindividual executive officers is to be decided by the Nominating and Compensation Committee.
Compensation for directors shall be linked to shareholder interests in order to provide
sufficient incentive for pursuing medium-to-long-term improvements in corporate value.
Compensation for directors (excluding external directors and directors who do not reside inJapan) comprises fixed basic compensation as well as performance-linked bonuses, which are basedon the performance of the Company in a given fiscal year to function as a short-term incentive, andperformance-linked stock-based compensation, which is based on the medium-to-long-term
performance of the Company to function as a medium-to-long-term incentive.
Benchmarks for compensation levels and the ratios of compensation are set based on theofficer compensation levels and the ratios of compensation of companies of a similar scale to
MARUI GROUP as determined using data from officer compensation surveys conducted by external

research firms. The Company’s compensation levels and ratios are checked against these benchmarks
each year. Ratios of compensation are discussed by the Nominating and Compensation Committeewith consideration paid to this basic policy and are then decided by the Board of Directors.
External directors will only receive fixed basic compensation based on their position toensure that they maintain an independent standpoint.
Compensation for Audit & Supervisory Board members will consist only of fixed basic
compensation and is to be decided through discussion among the Audit & Supervisory Board and set
within the limit approved at the ordinary general meeting of shareholders.
Article 21 (Training Policies)
4.14, 4.14.1, 4.14.2
The Board of Directors shall establish internal systems for providing directors, Audit & Supervisory
Board members, and executive officers with the training and information necessary for properly
fulfilling their roles and performing their duties.
Upon being appointed to their position, new directors, Audit & Supervisory Board members,
and executive officers shall undergo training on laws, finance, corporate governance, risk
management, and other matters.
Upon being appointed to their position, new external directors and external Audit &Supervisory Board members shall be provided with opportunities to receive information related to
the Company, such as that regarding its corporate philosophy, corporate culture, business activities,
finances, organizational characteristics, and other matters.
After being appointed to their position, directors, Audit & Supervisory Board members, andexecutive officers shall be provided with ongoing training opportunities based on their duties, skills,
and experience, and the Company will make necessary arrangements for the pursuit of education
opportunities outside the Company and cover any necessary expenses.
Article 22 (Independent Auditing Firm)
3.2, 3.2.1, 3.2.2
The independent auditing firm plays an important role in ensuring the reliability of information
disclosed by the Company and is expected to fulfill this responsibility toward shareholders and otherinvestors.
The independent auditing firm must maintain its independence from the Company.
The independent auditing firm must maintain a sufficient degree of expertise and mustensure the necessary level of quality in its accounting audits.
The Board of Directors and the Audit & Supervisory Board are to establish systems forenabling the independent auditing firm to coordinate with Audit & Supervisory Board members,
external directors, and internal audit divisions as necessary for appropriately performing its auditing
duties. In addition, the independent auditing firm is to be provided with opportunities to receive
information as needed from the president and representative director and from the CFO.
Quick action shall be taken in the event that the independent auditing firm detects

misconduct requiring a response by the Company or should other deficiencies be pointed out.
Article 23 (Risk Management System)
4.3, 4.3.4
From the perspective of Group management, the Board of Directors shall oversee the establishment
and implementation of frameworks for ensuring that internal control systems related to compliance,
the appropriateness of financial reports, and risk management are functioning effectively in order tofacilitate sound, transparent, and efficient management. Information on the operations of Group
companies, potential risk, and risk countermeasures are to be documented and monitored tominimize management risks and improve the effectiveness of internal control.
The Board of Directors, the Public Relations IR Committee, the Internal Control Committee,
the ESG Committee, the Information Security Committee, the Safety Control Committee, and theInsider Trading Prevention Committee shall be maintained in order to enhance controls related tomaterial management risks. Also, the Compliance Promotion Board, which is chaired by thepresident, shall be put in place to oversee these committees and to promote risk management acrossthe organization. Moreover, the Company shall adhere to policies including the MARUI GROUP
Information Security Policy, which sets specific policies for developing systems and formulating
measures to ensure the security of information assets, and the MARUI GROUP Tax Policy, whichclearly delineates guidelines for compliance with tax laws and minimization of tax risks (seeSupplementary Material 2 for more information).

Chapter 3 Relationship with Shareholders
Article 24 (Protection of Shareholder Rights)
General Principle 1, 1.1, 1.1.3
The Company shall take care to treat all shareholders, including minority and non-Japaneseshareholders, in an impartial manner that takes into account their shareholdings. In addition,
appropriate steps shall be taken to ensure that the voting rights at the ordinary general meeting ofshareholders and other shareholder rights are effectively protected.
Article 25 (Communication with Shareholders)
General Principle 5, 5.1, 5.1.1, 5.1.2, 5.1.3
The Company is to practice constructive communication with shareholders in order to realize
medium-to-long-term improvements in corporate value.
The Company is to improve upon its investor relations (IR) activities in order to facilitate
understanding with regard to its corporate philosophy, management strategies, business performance,and other matters.
Communications with shareholders are to advance through effective coordination between
the CFO and the executive officer in charge of investor relations and overseen by the president andrepresentative director.
Requests for individual meetings by shareholders are to be catered to as appropriate and asrationally feasible based on the details of the request and the purpose of the meeting with theInvestor Relations Division serving as the primary venue for handling such requests. Members ofmanagement, internal or external directors, or Audit & Supervisory Board members shall meet withshareholders as deemed appropriate based on their requests.
In order to facilitate constructive communication with shareholders, the Investor Relations
Division and other relevant divisions are to coordinate their efforts, periodically exchanging
information and sharing opinions based on specialized insight.
The invaluable opinions and requests received from shareholders through communication
activities will be reflected in meetings of the Board of Directors when appropriate.
The Company will periodically research the distribution of its shareholder base. The
findings will be used to enhance communication with shareholders by utilizing the communication
method that is most ideal for each different shareholder type.
In communicating with shareholders, the Company will comply with relevant laws
and regulations and manage insider information in an appropriate manner.
Article 26 (Ordinary General Meeting of Shareholders)
1.1.1, 1.1.3, 1.2, 1.2.2, 1.2.3, 1.2.4, 1.2.5, 3.1.2
Ordinary general meetings of shareholders shall be positioned as the highest-level forum for decision
making, and these meetings will be conducted in the manner that will best ensure shareholder desires
are reflected in management to the greatest degree possible.

Dates for ordinary general meetings of shareholders will be set to allow shareholders toappropriately exercise their voting rights. In order to guarantee that shareholders are provided with
sufficient time to consider the matters to be proposed at these meetings, notices of convocation ofordinary general meetings of shareholders will be made to contain accurate information and will, in
principle, be dispatched three weeks prior to meetings. In addition, notices of convocation will bemade available through electronic venues prior to dispatch.
English-language versions of notices of convocation of ordinary general meetings ofshareholders will be provided, and the Company will participate in a platform for electronic voting
rights exercise to improve shareholder convenience and thereby ensure all shareholders canappropriately exercise their voting rights.
The Company shall coordinate with trust banks in preparation for requests to exercise rights
at ordinary general meetings of shareholders from institutional investors whose shareholdings areunder the name of trust banks.
Should a large number of votes be lodged in opposition to a given proposal at an ordinary
general meeting of shareholders, the reasons for this opposition will be analyzed and the need forfurther measures will be examined by the Board of Directors.
Article 27 (Basic Policies for Capital Measures)
1.3, 1.6, 5.2
The Company is to conduct appropriate capital measures based on changes in its business structure
and on capital costs (shareholders’ equity costs and weighted average cost of capital). In the pursuitof improvements in corporate value, core operating cash flow is to be allocated in a balanced manner
to growth investments and shareholder returns. Return on equity is to be positioned as an importantmanagement indicator for which targets will be set. At the same time, the Company shall endeavor to
improve return on invested capital through earnings growth while developing a capital structure inwhich return on invested capital consistently exceeds capital costs (weighted average cost of capital)by transitioning to the optimal capital structure based on its business structure.
Prior to enacting capital measures that result in changes in controlling interests or significant
dilution of the stock base, the Board of Directors must first fully evaluate the necessity and rationaleof these measures. After this evaluation, the shareholders are to be provided with full explanations ofthese measures in accordance with the Companies Act of Japan and the Financial Instruments andExchange Act of Japan as well as the regulations of the Tokyo Stock Exchange, and related
procedures are to be conducted appropriately and through suitable means.
Article 28 (Shareholder Returns)
1.3
The Company shall maintain the basic policy of issuing appropriate and ongoing shareholder returns.
The Company will target high growth coupled with high returns by pursuing ongoingincreases in dividends through long-term growth in earnings per share.
A dividend on equity ratio of 8% will be targeted, as the Company institutes ongoingincreases in dividend payments over the long term.
After considering a comprehensive range of factors including financial conditions and shareprice, the Company shall take a flexible approach toward treasury stock acquisitions in order toincrease shareholder value. Acquired shares of treasury stock are, in principle, to be canceled.
Dividend and treasury stock acquisition policies will be reassessed regularly and revised asnecessary.
Article 29 (Cross-Shareholdings)
1.4, 1.4.1, 1.4.2
In principle, the Company will not engage in cross-shareholdings except for cases in which suchholdings are deemed necessary for maintaining or building upon collaborative or transactional
relationships that are strategically critical for improving corporate value.
The rationality of cross-shareholdings will be reassessed periodically, and holdings will be
confirmed annually by the Board of Directors. The results of these confirmations will be disclosed.
Shares for which the meaning of holding has been diminished may be sold in a phased manner after
considering the circumstances surrounding the counterparty.
Voting rights attached to shares held through cross-shareholdings will be exercised based on
thorough evaluation of each proposal and whether or not the proposal will contribute toimprovements in the medium-to-long-term corporate value of the Company. Consideration will also
be paid to the management policies of the counterparty.
The Company will not engage in transactions with companies that hold shares of its stock if
these transactions lack sufficient economic rationale. Should a company holding shares of stock in
the Company express intent to sell these shares, the Company will not impede those sales.
Article 30 (Related Party Transactions)1.7, 4.3
With regard to related party transactions, the Company has defined the following measures as meansof preventing damage to corporate value and the common interests of the shareholders of theCompany.
If a director plans to conduct a transaction that competes with the Company or represents a
conflict of interest, approval must be received from the Board of Directors in advance and a report isto be issued to the Board of Directors immediately upon conclusion of the transaction.
For other related party transactions, the appropriateness of conditions and decision-making
procedures for important transactions will be determined through discussion by the Board of
Directors.

Chapter 4 Others
Article 31 (Information Disclosure)
1.2.1, General Principle 3, 3.1.1, 3.1.2, 4.3, 5.2
The Company shall comply with all relevant laws and regulations and conduct timely andappropriate information disclosure to ensure that its management is both impartial and highly
transparent.
The Corporate Planning Division, the Investor Relations Division, the General Affairs
Department, and the Financial Department shall be the entities responsible for information
disclosure.
Both financial and non-financial information will be actively disclosed if deemed valuable
to shareholders and other investors seeking to deepen their understanding of the Company.
Information is to be disclosed through venues that are easy to access for shareholders andother stakeholders.
English-language versions of materials are made available when deemed necessary.
Article 32 (Internal Reporting System)
2.5, 2.5.1
The MARUI Group Hot Line (internal reporting system) is to be maintained as a means forpreventing the occurrence of legal violations or misconduct by organizations or individuals and forcorrecting any issues that may be discovered.
The MARUI Group Hot Line is to be operated in accordance with internal regulations and isto provide a venue for reporting to a consultation office inside the Group or to an outside lawyer. The
Company is to prevent reporters from suffering any detrimental treatment as a result of filing reports.
Article 33 (Changes to the Guidelines)
Any changes to the guidelines are to be instituted based on resolution by the Board of Directors.
(Supplementary Information)
The guidelines were enacted effective November 6, 2015.
On May 12, 2016, partial revisions were made in response to the establishment of the Nominating
and Compensation Committee.
On November 9, 2017, partial revisions were made to the MARUI GROUP Code of Conduct.
On June 25, 2018, partial revisions were made in response to revisions to Japan’s Corporate
Governance Code.
On May 14, 2019, the Sustainability Committee was established, the Company’s risk management
system was revised, and a partial revision to shareholder return policies was instituted.
On June 29, 2020, partial revisions were made to the MARUI GROUP Code of Conduct.
On August 5, 2021, partial revisions were made to the articles on Purpose; Code of Conduct; Duties
of Directors; Composition of the Board of Directors; Duties of Audit & Supervisory Board Members;

Sustainability Committee; Compensation of Directors, Audit & Supervisory Board Members, andExecutive Officers; Risk Management System; Communication with Shareholders; and Information
Disclosure. In addition, a new article on Sustainability Initiatives was established.
On November 11, 2021, an article regarding the Strategy Committee was established and partial
revisions were made to articles on Organizational Structure, the Sustainability Committee, and the
Risk Management System.
On April 19, 2022, an article regarding the Human Resource Strategy Committee was established.

(Supplementary Material 1)
Criteria for Independence of External Directors andAudit & Supervisory Board Members
4.9
MARUI GROUP aims to ensure the appropriate levels of objectivity and transparency necessaryfor effective corporate governance. For this reason, it has established the following criteria for
determining the independence of external directors, external Audit & Supervisory Board members,
and candidates for these two positions. Individuals that meet all of these criteria are judged to be
sufficiently independent from the Company.
1. The individual must not be a person involved in operation*1 of the Company, its subsidiaries, or
its affiliates and must not have been a person involved in operation during the past 10 years.
2. The individual must not be a major supplier*2 of the Company, its subsidiaries, or its affiliates ora person involved in operation of a major supplier.
3. The individual must not be a major customer*3 of the Company, its subsidiaries, or its affiliates
or a person involved in operation of a major customer.
4. The individual must not be a major shareholder of the Company possessing direct or indirect
holdings equating to 10% or more of voting rights or a person involved in operation of a major
shareholder.
5. The individual must not be a person involved in operation of an entity that possesses direct orindirect holdings equating to 10% or more of the total voting rights of the Company, its
subsidiaries, or its affiliates.
6. The individual must not be a consultant, a certified public accountant or other accounting
specialist, or a lawyer or other legal specialist receiving large amounts of monetary payments orother financial assets (more than ¥10 million) from the Company, its subsidiaries, or its affiliatesthat are separate from the compensation paid for services as a director or Audit & Supervisory
Board member. The individual also must not belong to a company or other organization thatreceives such payments or assets.
7. The individual must not receive large amounts of monetary payments or other financial assets(more than ¥10 million) as donations from the Company, its subsidiaries, or its affiliates andmust not belong to a company or other organization that receives such donations.
8. The individual must not be the accounting auditor of the Company. The individual also must notbelong to a company or other organization that serves as the accounting auditor of the Company.
9. The individual must not have been applicable under items 2. to 8. during the past five years.
10. The individual must not be a relative (one’s spouse or second-degree relatives) of an individualthat qualifies under items 2. to 8. (only applicable to relatives of important persons involved inoperation*4 for all items except items 6. and 8.).

11. The individual must not be a person involved in operation of another company at which aperson involved in operation of the Company, its subsidiaries, or its affiliates serves as anexternal director or Audit & Supervisory Board member.
Notes:*1 A “person involved in operation” is defined as an executive director, executive officer, or
employee with operational execution responsibilities of a stock company; a director of anon-company legal entity or organization; or individuals serving persons in similar positions orat similar companies, non-company legal entities, or organizations.
*2 A “major supplier” is defined as an entity that fulfills one of the following conditions:
1. A supplier group (the corporate group to which the supplier that serves as the directtransaction counterparty belongs) that provides products or services to the Company, its
subsidiaries, or its affiliates and for which transactions with the Company, its subsidiaries, andits affiliates equated to more than ¥10 million and represented more than 2% of the total
consolidated net sales (consolidated revenue) or transaction revenues of the supplier group in themost recently completed fiscal year.
2. A supplier group with which liabilities of the Company, its subsidiaries, or its affiliates areassociated and for which the applicable liabilities equated to more than ¥10 million andrepresented more than 2% of the consolidated total assets of the supplier group as of the end of
the most recently completed fiscal year.
*3 A “major customer” is defined as an entity that fulfills one of the following conditions:
1. A customer group (the corporate group to which the customer that serves as the directtransaction counterparty belongs) to which the Company, its subsidiaries, or its affiliates provide
products or services and for which the total amount of transactions with the customer groupequated to more than ¥10 million and represented more than 2% of the consolidated revenue of
the Company in the most recently completed fiscal year.
2. A customer group possessing liabilities that are associated with the Company, its subsidiaries,
or its affiliates and that equated to more than ¥10 million and represented more than 2% of theconsolidated total assets of the Company as of the end of the most recently completed fiscalyear.
3. A financial group (the financial group to which the customer that serves as the directtransaction counterparty belongs) from which the Company, its subsidiaries, or its affiliates
procure funds through borrowings and from which the total amount of funds borrowed
represented more than 2% of the consolidated total assets of the Company as of the end of themost recently completed fiscal year.
*4 “Important persons involved in operation” refers to directors, executive officers, and employeeswith operational execution responsibilities ranked as division manager or higher or individuals
with similar operational execution authority.

(Supplementary Material 2)

MARUI GROUP Policies
•
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•
•
•
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•
•
•
•
•
•
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Disclosure Policy
Anti-Corruption Policy
Tax Policy
Information Security Policy
Privacy Policy
Social Media Policy
Basic IT Service Management Policy
Procurement Policy
Human Rights Policy
Customer Engagement Policy
Occupational Health and Safety Policy
Human Resource Development Policy
Environmental Policy

MARUI GROUP Disclosure Policy
1. Basic Policy
MARUI GROUP pursues medium-to-long-term improvements in corporate value through constructive
exchanges with its stakeholders. To facilitate such exchanges, the Company engages in communication
with wide-ranging members of society and seeks to conduct highly transparent corporate activities
through timely and appropriate information disclosure.

2. Information Disclosure Standards
Information disclosure is conducted in accordance with the requirements described in the Companies Act,
the Financial Instruments and Exchange Act, and other laws and in the regulations of the Tokyo Stock
Exchange. MARUI GROUP actively discloses financial and pre-financial information (non-financial
information)* that has been deemed valuable to stakeholders seeking to deepen their understanding of theCompany, even if not necessitated by the aforementioned requirements.
*Pre-financial information: Information that has not yet impacted financial information but is still as
important as financial information

3. Information Disclosure Venues
Information that is legally mandated for disclosure is released through the venue described in theapplicable law, and information that must be disclosed in accordance with the timely disclosure
regulations of the Tokyo Stock Exchange is made available through the Timely Disclosure Network(TDnet). Information disclosed through these venues is also quickly uploaded to the Company’s
corporate website. Other information is disclosed on the corporate website or through other venues thatallow for easy access by stakeholders.

4. Enhancement of Investor Relations Activities
MARUI GROUP strives to enhance its investor relations activities in order to foster understanding withregard to its corporate philosophy, business strategies, and performance. Requests for individual meetingsby shareholders and other investors are catered to as appropriate and as rationally feasible based on thedetails of the request and the purpose of the meeting with the Investor Relations Department serving as
the primary venue for issuing such requests. The Company will periodically research the distribution ofits shareholder base. The findings will be used to enhance communication with shareholders and otherinvestors by utilizing the communication method that is most ideal for each different shareholder orinvestor type. In communicating with shareholders, the Company will comply with relevant laws andregulations and manage insider information in an appropriate manner. The input gained through such
communication is relayed to management and other relevant individuals within the Company so that it
can be utilized to pursue further improvements in corporate value.

5. Information Disclosure System
The entities responsible for information disclosure are the Corporate Planning Division, the Investor
Relations Department, the General Affairs Department, and the Financial Department. Information
regarding the proceedings within the Company and Group companies is reported at meetings of the Boardof Directors to facilitate the sharing of information. Information that is deemed necessary for disclosure
based on timely disclosure regulations is tracked through coordination between the relevant divisions andthe divisions responsible for information disclosure. For decisions made by the Board of Directors that
require timely disclosure, the Board of Directors will decide the details, timing, and method of disclosureand the representative responsible for information disclosure will perform the necessary procedures toensure prompt disclosure. Furthermore, the Public Relations IR Committee, which are compositioncommittee members of compliance promotion meetings chaired by the President and Representative
Director, confirms that appropriate information disclosure activities are carried-out in a timely andappropriate manner. In order to ensure fair and consistent disclosure, MARUI GROUP designates thepresident and representative director, the Chief Financial Officer, the general manager of the Investor
Relations Department, the chief manager of the Investor Relations Department and the general managerof the Financial Department as “spokespersons” who regularly interact and communicate withshareholders and other investors on behalf of the company. Meanwhile, to promote active disclosure of
pre-financial information, officers or employees other than these spokespersons may from time to timecommunicate with shareholders and other investors upon approval from a spokesperson.

6. Quiet Period
To prevent the leakage of financial results information and ensure impartial disclosure, the Company
observes a quiet period beginning 10 days prior to the final day of each quarter and ending with theannouncement of financial results. During this quiet period, the Company refrains from holding
individual meetings, answering media questions, and otherwise responding to inquiries. However, evenduring the quiet period, information on matters requiring disclosure based on timely disclosure
regulations will be promptly made available.

7. Third-Party Performance Forecasts
In principle, the Company does not offer any comments in regard to analyst reports and other third-party
opinions or performance forecasts. However, the Company may issue statements regarding reports, etc.,
issued by third parties that contain major factual errors or misrepresentations to identify these errors as
such.

Established in May 2016
Revised in May 2017
Revised in May 2018

Revised in August 2019

MARUI GROUP Anti-Corruption Policy
Basic Principles
MARUI GROUP aspires to harness the power of business to build a world that transcends dichotomies in its quest
to contribute to co-creating a flourishing and inclusive society that offers happiness to all. The foundation for thisquest must be grounded in strong corporate governance and sound and highly transparent management. TheMARUI GROUP Anti-Corruption Policy was established to guide efforts to build this foundation. MARUI GROUP
is committed to honest corporate activities that are compliant with laws and regulations, adherent to social ethics,
and free of abuses of authority or position, unethical behavior, and all other forms of corruption, including bribery,
inappropriate kickbacks, money laundering, conflicts of interest, bid-rigging, fraud, inappropriate lobbying
activities, and political contributions.

1. Scope of Application
This policy is applicable to all MARUI GROUP officers and employees. In addition, all business partners are
asked to implement measures for preventing corruption.

2. Anti-Corruption Management
Initiatives for preventing corruption at MARUI GROUP will be reviewed appropriately based on the MARUIGROUP Anti-Corruption Policy by the Compliance Promotion Board, which is chaired by the president andrepresentative director, and the results of these reviews will be reported to the Board of Directors. The
Compliance Promotion Board oversees the Internal Control Committee and the Insider Trading Prevention
Committee and receives reports from these committees as part of its duties in managing Groupwide risks. Under
this system, anti-corruption management will be conducted by raising the awareness of all officers andemployees through the implementation of divisional anti-corruption initiatives. The MARUI GROUP
Anti-Corruption Policy and the Company’s anti-corruption initiatives will be reviewed as appropriate.

Anti-Corruption Awareness Raising
MARUI GROUP seeks to increase the effectiveness of the MARUI GROUP Anti-Corruption Policy by
spreading awareness with regard to the policy and the MARUI GROUP Code of Conduct. Anti-corruption andcompliance training and education programs are instituted targeting all employees, and individual training
sessions tailored to the characteristics of specific businesses and work processes are conducted regularly.

Risk Management
MARUI GROUP takes steps to prevent corruption through its internal control system. Details on the operationsof Group companies, the projected risks, and the related response measures are documented and monitored, andinternal audits are conducted to confirm the effectiveness of initiatives.
Reporting venues (whistleblowing systems) have been set up for the employees of business partners and Groupcompanies to facilitate measures for preventing and addressing organizational and individual legal violations andmisconduct.
Whistleblowers can submit anonymous reports to the Audit Department or submit reports under their realname to an outside legal firm, in which case the legal firm will conceal the identity of the whistleblower whenreporting the complaint to the Company. The confidentiality of whistleblowers is protected as legally mandated
to prevent disadvantageous treatment of them as a result of their reporting.
Should acts of corruption be detected, harsh disciplinary measures and other actions will be taken basedon internal regulations, and measures will be implemented to prevent recurrence of such acts.

Information Disclosure
MARUI GROUP discloses information on acts of corruption and anti-corruption measures in a timely manner.

Code of Conduct
1. Legal Compliance
MARUI GROUP conducts its corporate activities in compliance with the Unfair Competition Prevention
Act and the Antimonopoly Act of Japan as well as with other bribery and anti-corruption laws andregulations of relevant countries.

2. Fair and Ethical Business Activities
MARUI GROUP acts in accordance with domestic and overseas social norms and laws and internal
regulations based on this policy and the MARUI GROUP Code of Conduct to prevent acts of corruption
and ensure its business activities are fair and ethical.

Relationships with Business Partners
By fostering trusting relationships with partners through fair and impartial transactions, MARUI GROUP
deepens its ties with business partners as it progresses together with them and promotes mutual prosperity.
MARUI GROUP is committed to sound procurement transactions, fair outsourcing transactions, and free and faircompetition with regard to sales and marketing. We also refuse to engage in behavior that violates the rights ofbusiness partners or constitutes abuse of a dominant bargaining position.
Corruption risks are assessed when engaging in new transactions or investments. Should acts of corruption be
confirmed, the Company will decide whether to revise or discontinue transactions as appropriate.

Relationships with Politicians and Government Agencies
MARUI GROUP strives to maintain healthy and sound relationships with politicians and government agencies.
The Company does not take part in bribery, including facilitating payments,* of politicians and government
officials and does not, in principle, make political contributions.
* Small payments paid for no purpose other than for facilitating favorable outcomes with regard to government
servicesRelationships with Other Organizations
MARUI GROUP does not take part in inappropriate monetary exchanges when making donations to government
lobbying campaigns or to nonprofit, philanthropic, or other organizations through industry organizations.

Opposition of Antisocial Forces
MARUI GROUP shall refuse all relationships with antisocial forces that threaten social safety and order or withorganizations or individuals who have relationships with such antisocial forces. Moreover, the Company will not
engage in transactions that are in anyway related to antisocial forces.

3. Prohibition of Pursuit of Personal GainMARUI GROUP prohibits the misuse of Company positions or of information obtained during the courseof business activities for the purpose of pursuing personal gain. This stance is buttressed by measures
such as internal regulations and employee education programs for the purpose of ensuring legal
compliance and observance of social ethics.

Conflicts of Interest
If a Group officer plans to conduct a transaction that competes with the Company or represents a conflict ofinterest, approval must be received from the Board of Directors in advance and a report be issued to the Board of
Directors immediately upon conclusion of the transaction. When an employee is at risk of being influenced by a
conflict between the interests of the Company and the interests of themselves, a family member, or another third
party, this fact should be immediately reported to the Company so that appropriate steps can be taken to alleviate
the conflict of interests.

Misappropriation and Fraud
Internal regulations are in place to prevent misconduct and to protect Company assets. All officers andemployees are expected to abstain from activities resulting in inappropriate gains being transferred to themselves
or to other parties, including personal misappropriation, embezzlement, and fraudulent billing.

Insider Trading
MARUI GROUP has established the Insider Trading Prevention Committee and conducts training and education
for all officers and employees along with other measures for preventing insider trading. Transactions involving
shares of the stock of the Company or of other listed companies are prohibited if they are based on undisclosed
information obtained during the course of business activities. Individuals in positions that are privy to such
undisclosed information are expected to be rigorous in their management of this information to prevent it frombeing communicated to unrelated parties prior to disclosure.

Established in March 2021

Hiroshi Aoi
President and Representative Director
Representative Executive Officer, CEOMARUI GROUP CO., LTD.

MARUI GROUP Tax Policy
Basic Policy
MARUI GROUP (the Company and its subsidiaries and affiliates) practices co-creation sustainability management
together with its stakeholders to help build a flourishing and inclusive society that offers happiness to all.
Complying with tax laws and paying appropriate taxes contributes to communities and to the greater society and istherefore congruent with MARUI GROUP’s concept of co-creation sustainability management. Based on thisrecognition, MARUI GROUP has established tax policies and seeks to exercise its responsibility to make tax
payments based on the circumstances of its business and to ensure transparency in its tax payments in order tominimize tax risks.

1. Legal Compliance
MARUI GROUP shall comply with laws and regulations pertaining to taxes to appropriately fulfill its
obligation to pay taxes.
Accordingly, MARUI GROUP will not take advantage of tax deductions or other provisions that do notmatch the circumstances of its business or use regions deemed to be “tax havens” in order to avoid
paying taxes. In international transactions, MARUI GROUP will adhere to the tax laws and tax treaties of
the relevant countries as well as to international taxation rules.

2. Transparency
MARUI GROUP shall comply with all applicable accounting standards and disclosure standards topractice appropriate disclosure of information to all stakeholders. At the same time, MARUI GROUP
shall cooperate with tax authorities by providing all information requested in order to build strong,trusting relationships with these authorities. Should a tax-related issue be discovered, MARUI GROUP
will take quick action to rectify the issue and prevent recurrence.

3. Minimization of Tax Risks
MARUI GROUP shall endeavor to minimize tax risks based on accurate understanding of tax systems inorder to improve corporate value.
When transactions made during the course of business activities involve unclear tax reporting methods,
MARUI GROUP will seek consultation from specialists, thoroughly examine the transactions, andreceive confirmation from tax authorities as deemed necessary to reduce tax risks.

4. Tax Functions and Governance
Procedures related to taxes will be performed by accounting representatives designated based on internal
regulations.
Tax governance systems shall be headed by the chief finance officer (CFO) of MARUI GROUP CO.,LTD., and accounting representatives shall report on the status of accounting and tax-related procedures

as necessary. Oversight of tax-related procedures is to be provided by the Audit & Supervisory Board andauditing divisions, which shall include members with specialized insight with regard to areas such as
finance, accounting, and legal affairs.

Established on June 25, 2018

MARUI GROUP Information Security Policy
MARUI GROUP (the Company and its subsidiaries and affiliates) practices co-creation management, which entails
co-creating the happiness of its customers and other stakeholders through business activities merging retailing andfinance. This undertaking entails collecting information on customers as well as other information assets. For thisreason, strengthening Groupwide information security to protect these assets from unauthorized access,cyberattacks, and other threats is among the most important tasks for management.
In light of this recognition, MARUI GROUP has established the following MARUI GROUP Information
Security Policy based on the MARUI GROUP Code of Conduct. MARUI GROUP officers and employees are
expected to act and handle information assets in compliance with this policy as well as with the separate MARUIGROUP Privacy Policy and MARUI GROUP Social Media Policy in order to contribute to improved information
security.

1. Purpose
The purpose of this policy is to provide guidelines for establishing and implementing information
security management systems to protect the information assets of customers and of MARUI GROUP
from all threats, whether internal or external, accidental or intentional, and thereby help ensure thecontinuity of MARUI GROUP’s business activities.

2. Basic Principles(1) MARUI GROUP shall practice appropriate management of the information entrusted to it byindividuals or organizations during the course of its business activities while respecting the rights andinterests of these individuals or organizations.
(2) MARUI GROUP shall practice appropriate management of trade secrets, technological information,and other valuable information acquired during the course of its business activities and protect therights and interests of MARUI GROUP.
(3) MARUI GROUP will engage in research and human resource development in order to work to
improve information security as it pertains to customer information and thereby gain greater levels oftrust from customers and subsequently society as a whole.

3. Scope of Application
This policy is applicable to all MARUI GROUP officers and employees.

4. Definition of Information Security(1) MARUI GROUP defines information security as precautions for protecting the information assets of
MARUI GROUP from threats with the potential to impact the confidentiality, completeness, andavailability of these assets. Cybersecurity is one facet of information security.
(2) MARUI GROUP defines cybersecurity as safety precautions necessary for preventing information

from being leaked, destroyed, or damaged; provisions for ensuring the safety and reliability of
MARUI GROUP’s information systems and telecommunications networks; and measures for
ensuring proper maintenance and management of these provisions.

5. Information Security Provisions
Recognizing the various risks that may threaten information security during the course of its business,
MARUI GROUP shall implement the following information security provisions.

(1) Risk management pertaining to IT systems for the entire Group shall be overseen by the Compliance
Promotion Board, which is to be chaired by the president and representative director of MARUIGROUP CO., LTD.
(2) MARUI GROUP shall establish an Information Security Committee tasked with maintaining an
accurate understanding of circumstances pertaining to information security and discussing
information security measures. The Information Security Committee shall submit reports on its
activities to the Compliance Promotion Board in order to facilitate the swift implementation ofGroupwide information security measures.
(3) MARUI GROUP shall appoint a chief security officer (CSO) to serve as the highest-level authority on
security responsible for promoting appropriate management and protecting Groupwide information
assets. Responsibility and authority for the implementation of information security measures at
MARUI GROUP shall be entrusted to the CSO.
(4) The CSO shall issue reports on the execution of their duties to the Board of Directors of MARUIGROUP CO., LTD., and to the Compliance Promotion Board when deemed necessary.
(5) The president and representative director of M & C SYSTEMS CO., LTD., a Group company that is
responsible for the management and operation of the Group’s information security systems, shallserve as the chief information officer (CIO).
(6) The MARUI GROUP Hot Line (internal reporting system) is to be maintained as a means forpreventing the occurrence of legal violations or misconduct by organizations or individuals and forcorrecting any issues that may be discovered. The MARUI GROUP Hot Line is to be operated inaccordance with internal regulations and is to provide a venue for reporting to the Audit Departmentof MARUI GROUP CO., LTD., or to an outside lawyer. MARUI GROUP is to prevent reporters from
suffering any detrimental treatment as a result of filing reports.

6. Information Security Measures(1) Information security frameworks
MARUI GROUP shall formulate action plans for addressing information security risks and conduct
evaluations to assess whether or not these plans are being effectively implemented. In addition, aframework will be put in place to facilitate ongoing improvements through a PDCA
(plan–do–check–act) cycles cycle.

(2) Compliance with internal regulations and laws
MARUI GROUP shall establish internal regulations for ensuring effective information security
measures and disseminate these regulations among officers and employees. Harsh penalties shall belevied against individuals that are found to be in violation of internal regulations or laws related to
information security.
(3) Resource managementi.

MARUI GROUP shall secure and allocate the management resources necessary for
implementing appropriate information security measures.

ii.

MARUI GROUP shall recruit and develop the human resources necessary for implementing
appropriate information security measures in a systematic and ongoing manner.

iii.

MARUI GROUP shall provide education on information security to officers and employees topromote awareness of the importance of information security and encourage action in thisregard.

iv.

MARUI GROUP shall actively participate in external forums for exchanges of information andreflect the information gained in its information security measures.

(4) Sharing of information security policies with business partners
MARUI GROUP shall share its information security policies with tenants, affiliates, subcontractors,
and other business partners and request that they practice appropriate information security inaccordance with these policies.
(5) Information disclosure
MARUI GROUP shall practice appropriate disclosure of its information security initiatives in order togain greater levels of trust from its stakeholders.
(6) Implementation and enhancement of auditing systems
MARUI GROUP shall conduct audits of its information security systems periodically and asnecessary to verify that it is in compliance with all laws, government and industry organization
standards, and internal rules and regulations related to information security in its operations and thatthese information security systems are functioning appropriately. Harsh penalties shall be levied in
response to any violations found to ensure effective management of information.
(7) Systems reflecting information security measures
MARUI GROUP shall develop systems that reflect its information security measures for preventing
unauthorized access, destruction, leakage, alteration, or other incidents affecting information assets.
(8) Improvement of information security literacy
MARUI GROUP shall continually conduct education and training programs to improve theinformation security literacy of officers and employees and support effective management of
information assets across the Group.

7. Protection of Personal Information of Customers
MARUI GROUP shall conduct personal information protection activities based on the MARUI GROUP

Privacy Policy, which defines policies for handling personal information in all business activities, toprotect personal information and implement the necessary information security measures.

8. Response to Information Security Incidents
In the event that an information security risk materializes (an information incident occurs), MARUIGROUP shall respond through the following frameworks and response policies.

(1) MARUI GROUP shall identify the lines of reporting and create initial response manuals regarding
information security incidents. Awareness regarding these provisions shall be entrenched among
relevant personnel and regular, practical drills shall be conducted.
(2) In the event that a major information security incident occurs, the head of the division that detected
the incident shall promptly report to the chairperson of the Information Security Committee and to the
CSO.
The chairperson of the Information Security Committee shall then report to the CIO, and the CSO
will report to the president and representative director of MARUI GROUP CO., LTD., as necessary.
(3) When the CSO receives a report of a serious information security incident, a task force will beassembled under the guidance of the CSO to respond to the incident.
(4) When the president and representative director of MARUI GROUP CO., LTD., receives a report of an
emergency incident, they will promptly set up a response headquarters when necessary. This response
headquarters will work to quickly resolve the issue, identify its cause, and formulate and implement
measures to prevent recurrence.
(5) Notification will be submitted to the relevant government authorities and to other related parties asnecessary in the event of an information security incident.

9. Revision or Abolishment of This Policy
This policy is to be reviewed as necessary by the Board of Directors of MARUI GROUP CO., LTD.,and revised or abolished when deemed prudent through sufficient discussion.
Minor revisions, such as changes to organization names, may be made at the discretion of the CSO.

10. Ongoing Improvement
MARUI GROUP shall regularly evaluate the aforementioned provisions and make revisions asnecessary to implement ongoing improvements to its information security measures in response tochanges in external and internal information security trends and IT technologies.

11. Third-Party Evaluation and Certification(1) Information Security Management Certification (ISO 27001)
The Data Center Division of M & C SYSTEMS CO., LTD., received information security
management system certification in 2006. In March 2007, after the development of international

standards as well as standards set by the Japanese Industrial Standards Committee (JISC) related to
information security management systems, ISO 27001 certification was acquired.
(2) IT Service Management Certification (ISO 20000)
In April 2008, ISO 20000 certification was acquired with regard to the product sales and distribution
systems of MARUI CO., LTD., and the core operating systems of Epos Card Co., Ltd. The ability toacquire this certification was a reflection of MARUI GROUP’s swift response to system malfunctions,its provisions for preventing recurrence of incidents, and other factors that contribute to the highquality of its services.
(3) PrivacyMark Certification (JIS Q 15001)
Group companies M & C SYSTEMS CO., LTD.; Epos Card Co., Ltd.; AIM CREATE CO., LTD.;
MOVING CO., LTD.; MRI Co., Ltd.; and MARUI HOME SERVICE Co., Ltd., handle personal
information in the course of their businesses. The personal information management systems of thesecompanies are compliant with JISC standards and have been certified by JIPDEC, granting thesecompanies permission to use the PrivacyMark.

Established on June 25, 2018

MARUI GROUP Privacy Policy
MARUI GROUP (the Company and its subsidiaries and affiliates) collects personal information on its customers
and other stakeholders in order to provide services that satisfy customers through its business activities. This
personal information is an important asset to the ongoing growth of MARUI GROUP. Accordingly, the appropriate
management of such information is a major management responsibility. MARUI GROUP has therefore establishedthe MARUI GROUP Privacy Policy to function as a shared Groupwide policy for guiding efforts to appropriately
manage and protect all personal information collected by MARUI GROUP.

1. Scope of Application
The MARUI GROUP Privacy Policy is applicable to all MARUI GROUP officers and employees. We
also request that our business partners adhere to this privacy policy.
2. Information Security
MARUI GROUP appoints a chief security officer to promote the protection and appropriate managementof Groupwide information assets. The chief security officer is assigned responsibility and authority forthe execution of all MARUI GROUP information security measures related to the protection andappropriate management of personal information as well as other information security tasks. Moreover,the Information Security Committee has been put in place to monitor the status of information security
and to discuss the necessary measures. This committee submits reports on its activities to the Compliance
Promotion Board, which is chaired by the president. These provisions make for a framework that allows
for the swift implementation of Groupwide information security measures.

3. Acquisition, Use, Provision, and Outsourced Handling of Personal Information
MARUI GROUP shall collect information through legitimate methods, clearly explaining the purpose forwhich the collected information will be used as opposed to relying on deception or other wrongful means.
Collected personal information will only be used for the purpose initially agreed upon, and appropriate
management will be practiced while implementing measures to prevent such information from being used
for other purposes.
MARUI GROUP will not provide personal information to a third party without consent from theindividual in question except when lawfully requested by public institutions or in other cases mandatedby law. When contracting third parties to perform the handling of personal information, MARUI GROUP
will select entities that have sufficient measures in place to protect personal information and ensure that
this information is managed appropriately by including stipulations pertaining to the protection of
personal information in contracts and other agreements.

4. Measures for Protection of Personal Information
MARUI GROUP shall take steps to prevent unauthorized access, destruction, damage, or leakage of
personal information. In the event that an information security incident occurs, swift action will be taken

to address this incident. In addition, MARUI GROUP shall establish rules regarding the appropriate
management and use of personal information, appoint individuals responsible for managing suchinformation, and provide thorough training to Group officers and employees. Audits of divisions as well
as of first- and second-tier subcontractors tasked with handling personal information are conducted as
appropriate and necessary for protecting personal information.

5. Compliance with Laws and Standards Regarding Personal Information
MARUI GROUP shall comply with laws such as Japan’s Act on the Protection of Personal Information,national policies, and other standards regarding the handling of personal information. In addition, internal
regulations and manuals are prepared to facilitate compliance with the MARUI GROUP Privacy Policy,
and adherence to these provisions is expected. Disciplinary and other measures will be taken as
appropriate should a leak of personal information or other information security incident occur.

6. Continuous Improvement of Personal Information Management Systems
MARUI GROUP shall develop, implement, and continuously improve personal information management
systems to ensure that personal information is protected.

7. Inquiries Regarding Personal Information
MARUI GROUP shall respond to any inquiries regarding the disclosure, revision, or deletion of personal
information as well as any complaints or consultations from individuals or proxies acting on behalf ofindividuals pertaining to personal information it has collected.

8. Use of Cookies
MARUI GROUP uses cookies for some of the content provided on its websites. Cookies are files saved
in a user’s browser when they access a website. These files do not contain information that could be used
to identify a specific individual. However, there are cases in which this information may be used inconjunction with other information in a way that could be used to identify a specific individual. MARUIGROUP will only acquire and use information in these cases after receiving consent from the individualin question or after confirming that prior consent has been received as stipulated in the Act on theProtection of Personal Information and in the relevant guidelines.
It is possible to disable the use of cookies by adjusting one’s browser settings. Should a user disable theuse of cookies, it may impact their ability to view certain parts of MARUI GROUP websites.

9. Revision of Privacy Policies
Information on important changes to the MARUI GROUP Privacy Policy will be provided through
MARUI GROUP’s corporate website. Should a revision to the MARUI GROUP Privacy Policy be
implemented, the revised policy will be applied effective from the date that the revised policy isdisclosed.

Group Companies with Privacy Policies

MARUI GROUP CO., LTD.
Epos Card Co., Ltd. (Japanese only)
MARUI CO., LTD.
M & C SYSTEMS CO., LTD. (Japanese only)
MARUI FACILITIES Co., Ltd. (Japanese only)
MOVING CO., LTD. (Japanese only)
MRI Co., Ltd. (Japanese only)
AIM CREATE CO., LTD. (Japanese only)
MARUI HOME SERVICE Co., Ltd. (Japanese only)
Epos Small Amount and Short Term Insurance Co., Ltd. (Japanese only)
tsumiki Co., Ltd. (Japanese only)
D2C & Co. Inc. (Japanese only)
okos Co., Ltd. (Japanese only)

Privacy Policy of MARUI GROUP CO., LTD.
MARUI GROUP CO., LTD., has defined the following policies for the management of personal information
including the names, addresses, and email addresses of customers, business partners, shareholders, officers, andemployees.
The terms used in these policies are based on the definitions put forth by the Act on the Protection of
Personal Information and other relevant legislation. Personal information acquired by Group companies other than
MARUI GROUP CO., LTD., and other personal information defined as applicable for management under the
regulations of these companies shall be managed in accordance with the regulations of each company.
1. Company Name, Address, and Representative
MARUI GROUP CO., LTD.
3-2, Nakano 4-chome, Nakano-ku, Tokyo 164-8701, Japan
Hiroshi Aoi, President and Representative Director, Representative Executive Officer

2. Compliance with Relevant Legislation, Guidelines, etc.
MARUI GROUP shall manage personal information appropriately and in compliance with the Act on theProtection of Personal Information and other relevant legislation as well as the guidelines and otherstandards set forth by the Company’s Personal Information Protection Promotion Committee and thisprivacy policy.

3. Collection of Personal Information
MARUI GROUP shall only collect personal information through appropriate and legal means.

With regard to information classified as “special care-required personal information” in the Act on theProtection of Personal Information, expressed consent must be received from the individual in question
prior to collecting such information.
Furthermore, MARUI GROUP will only collect and use “Individual Numbers” and “Specific Personal
Information” as defined in the Act on the Use of Numbers to Identify a Specific Individual in
Administrative Procedures for the purposes permitted under this law.

4. Purposes of Use of Personal Information
MARUI GROUP will only use collected personal information for the following purposes or for purposesthat are clear from the method through which this information was collected. Personal information will
not be used for other purposes without expressed consent from the individual in question except in cases
when such usage is permitted by law.

Purposes of Uses for Personal Information of Customers and Business Partners(1) Use for confirmation and verification of identity of customers and business partners(2) Use for the purpose of performing transactions in the retailing, fintech, or other businesses of MARUIGROUP or in performing related procedures(3) Use for the purpose of supplying information related to products, services, or other offerings of thebusinesses of MARUI GROUP*(4) Use for the purpose of responding to inquiries or consultations from customers or business partners(5) Use for improvement of digital services (websites, apps, etc.) provided by MARUI GROUP based on
input received via surveys and other means(6) Use for the purpose of performing procedures associated with the above items* MARUI GROUP may perform analyses of website viewing records, purchase histories, and otherinformation acquired from customers or may link preference, website viewing records, and otherinformation acquired from third parties to customer information held by the Company in order to
distribute advertisements regarding products, services, and other offerings.

Purposes of Uses for Personal Information of Shareholders or Employees of Shareholders(1) Use for the purpose of exercising rights or obligations defined by the Companies Act of Japan(2) Use for the purpose of supplying information regarding the businesses of MARUI GROUP(3) Use for the purpose of facilitating discussion with shareholders regarding the businesses of MARUIGROUP(4) Use for the purpose of providing shareholder and other benefits from MARUI GROUP(5) Use for the purpose of managing shareholders in accordance with relevant legislation(6) Use for the purpose of responding to inquiries or consultations from shareholders

Purposes of Uses for Personal Information of Officers and Employees of MARUI GROUP CO., LTD.,
and Group Companies(1) Use for business-related communications(2) Use for the purpose of payment of compensation (salaries, bonuses, allowances, etc.), execution ofhuman resource or labor management tasks, or provision of welfare benefits(3) Use for the purpose of promoting occupational health and safety, health, and healthcare management(4) Use for the purpose of performing procedures related to social health insurance or other welfare
programs(5) Use for the purpose of performing other procedures related to officers and employees

5. Joint Usage of Personal Information
Joint usage of names, addresses, email addresses, business cards, and other personal informationcollected from customers and business partners may be conducted between MARUI GROUP CO., LTD.,
and Group companies in order to realize more comprehensive use of personal information for the
purposes described in “Purposes of Uses for Personal Information of Customers and Business Partners”
under “4. Purposes of Use of Personal Information” above. Joint usage of personal information collectedby Group companies will be conducted in accordance with the relevant regulations of the companies
engaged in joint usage. Joint usage will not be conducted with regard to information for which such use isprohibited by the regulations of the relevant companies.

The following Group companies engage in joint usage of personal information.

MARUI GROUP CO., LTD.
Epos Card Co., Ltd.
MARUI CO., LTD.
M & C SYSTEMS CO., LTD.
MARUI FACILITIES Co., Ltd.
MOVING CO., LTD.
MRI Co., Ltd.
AIM CREATE CO., LTD.
MARUI HOME SERVICE Co., Ltd.
Epos Small Amount and Short Term Insurance Co., Ltd.
tsumiki Co., Ltd.
D2C & Co. Inc.
okos Co., Ltd.

The company responsible for management of personal information used jointly is as indicated in “1. Company
Name, Address, and Representative” above.

In addition to the above, joint usage of personal information collected from officers and employees of
MARUI GROUP CO., LTD., and Group companies may be conducted between MARUI GROUP CO.,LTD., MARUI GROUP’s health insurance union, and MARUI GROUP UNION in order to achieve morecomprehensive use of personal information for the purposes described in “Purposes of Uses for Personal
Information of Officers and Employees of MARUI GROUP CO., LTD., and Group Companies” under “4.
Purposes of Use of Personal Information” above. MARUI GROUP CO., LTD., shall be responsible forthe management of personal information used jointly in this manner.

6. Subcontracting of Personal Information Handling
MARUI GROUP may subcontract the handling of personal information it has collected to third parties inorder to facilitate smooth operations or the provision of higher quality services to customers or
shareholders. In these cases, the personal information provided will be limited to the minimum amountnecessary to perform the tasks for which the third party is contracted.

7. Provision of Personal Information to Third Parties
Personal information will not be provided to third parties (with the exception of cases involving
subcontractors handling personal information) without advance consent from the individual in question
except when lawfully requested by public institutions or in other cases mandated by law.
8. Security Control Measures
MARUI GROUP implements security control measures as necessary and appropriate for the managementof personal information to prevent destruction, damage, or leakage of such information. In addition,
oversight of divisions as well as of first- and second-tier subcontractors tasked with handling personal
information is practiced as appropriate and necessary for this purpose.

Personal Information Protection Policies•This privacy policy stipulates the need for compliance with relative legislation, guidelines, and otherprovisions for ensuring the appropriate management of personal information as well as the venues forprocessing of questions and complaints.

Personal Information Management Regulations• MARUI GROUP has established regulations for handling personal information that stipulate themanagement procedures and responsible parties for personal information-related processes includingcollection, use, storage, provision, deletion, and disposal.

Organizational Security Control Measures• Personal information security control execution management representatives and oversight
representatives are appointed, and the employees responsible for the handling of personal information as
well as the scope of information for which they are responsible are clearly defined. Systems are in place
for reporting any detected violations or signs of potential violations of the Act on the Protection of
Personal Information or of personal information-related regulations to the personal information security
control oversight representatives.
• Regular self-checks as well as audits by auditing divisions are performed with regard to the status of
personal information management.

Human Resource-Level Security Control Measures• Regular employee training is held detailing the matters requiring caution with regard to the handling of
personal information.
• Provisions regarding the confidentiality of personal information are included in work regulations.

Physical Security Control Measures• Management of access to areas in which personal information is handled is practiced and restrictions on
the devices that can be taken into these areas are implemented as necessary, and measures are in place toprevent unauthorized viewing of personal information.
• Measures are in place to prevent the theft or loss of devices, electronic media, or documents containing
personal information. In addition, steps are taken to prevent easy identification of personal information
on such devices, electronic media, and documents during transport within business sites or elsewhere.

Technological Security Control Measures• Access restrictions are instituted to limit the scope of individuals with responsibility for handlingpersonal information as well as the scope of personal information databases.
• Frameworks have been introduced to protect systems processing personal information fromunauthorized external access or unauthorized software.

Tracking of External Conditions• When personal information is stored overseas, MARUI GROUP shall implement security control
measures based on an accurate understanding of the requirements regarding the protection of personal
information in the respective countries.

Note: Please click here for information regarding personal information stored overseas and the associatedsecurity control measures.
9. Continuous Improvement of Personal Information Management Systems
MARUI GROUP shall develop, implement, and continuously improve personal information management
systems to ensure that personal information is protected.

10. Requests for Disclosure, etc., of Possessed Personal Information
MARUI GROUP shall respond promptly to any requests for the disclosure, revision, ceased use, ordeletion of personal information for reasons stipulated in the Act on the Protection of Personal
Information upon confirming that the requesting individual is indeed the individual to whom said
information relates. For information on the process for requesting such action, please refer to “Process for
Requesting Disclosure, etc., of Possessed Personal Information” below.

Questions regarding the process for requesting disclosure or other actions pertaining to possessed
personal information or other aspects of this privacy policy should be directed to the contact venue
indicated in “13. Contact Venue for Inquiries” below.

Process for Requesting Disclosure, etc., of Possessed Personal Information
Requests for the disclosure or other actions pertaining to possessed personal information shall beprocessed via regular mail. When submitting such requests, please enter the required information in thedisclosure, etc., request form available below and mail it together with a copy of a publicly recognized
proof of identification that can be used to verify the identity of the requester (driver’s license, certificate
of residence, etc.) to the contact indicated in “13. Contact Venue for Inquiries” below. The proxy
disclosure, etc., request form should be used when submitting a request as a proxy of the individual inquestion. Personal information acquired as part of the process for requesting disclosure or other actions
pertaining to possessed personal information shall only be used as necessary for the purpose ofprocessing the given request.
・Disclosure, etc., request form (PDF)
・Proxy disclosure, etc., request form (PDF)

11. Handling of Anonymized Information(1) When creating anonymized information, MARUI GROUP shall take the necessary steps to ensure thatthe individuals with whom the information is associated cannot be identified and that the original
personal information cannot be reproduced.
(2) When using anonymized information, MARUI GROUP will not compare this information to otherinformation for the purpose of identifying the individuals with whom the anonymized information isassociated.
(3) Items regarding the individuals whose personal information was used by MARUI GROUP to create
anonymized information will be disclosed as required by relevant legislation.
(4) When providing anonymized information to third parties, MARUI GROUP shall disclose items
regarding the individuals whose personal information was used to create the anonymized informationand the purpose for which this information was provided as required by relevant legislation. In
addition, MARUI GROUP shall inform the third party of the fact that the information has beenanonymized.
12. Use of Cookies
MARUI GROUP uses cookies for some of the content provided on its websites. Cookies are files saved
in a user’s browser when they access a website. These files do not contain information that could be used
to identify a specific individual. However, there are cases in which this information may be used inconjunction with other information in a way that could be used to identify a specific individual. MARUIGROUP will only acquire and use information in these cases after receiving consent from the individualin question or after confirming that prior consent has been received as stipulated in the Act on theProtection of Personal Information and in the relevant guidelines.
It is possible to disable the use of cookies by adjusting one’s browser settings. Should a user disable
the use of cookies, it may impact their ability to view certain parts of MARUI GROUP websites.
13. Contact Venue for Inquiries
Please contact the following venue for questions or complaints regarding the handling of personal
information by MARUI GROUP as well as for requests for disclosure or other actions pertaining topossessed personal information as described in “10. Requests for Disclosure, etc., of Possessed Personal
Information” above.

Contact Venue
Compliance and Legal Affairs Section, General Affairs Department, MARUI GROUP CO., LTD.
Email Addressprivacy@0101.co.jp
Address for Submitting Requests for Disclosure, etc., of Possessed Personal Information
3-2, Nakano 4-chome, Nakano-ku,
Tokyo 164-8701, Japan

14. Revision of Privacy Policy
This policy is to be reviewed as necessary by the Board of Directors and revised when deemed prudent
through sufficient discussion. Minor revisions, such as changes to organization names, may be made atthe discretion of the chief security officer. Information on important changes to this policy will be
provided through MARUI GROUP’s corporate website. Upon revisions, the revised privacy policy shallbe applied effective as of the date of announcement.

Established on June 25, 2018
Revised on September 20, 2019
Revised on March 2, 2020
Revised on April 14, 2021

Revised on April 1, 2022

MARUI GROUP Social Media Policy
MARUI GROUP (the Company and its subsidiaries and affiliates) utilizes social media as a communication tool for
facilitating co-creation activities with all of its stakeholders. MARUI GROUP has established and complies withthe following policies regarding the operation of official social media accounts and private social media use byGroup officers and employees.

1. Basic Policies
MARUI GROUP officers and employees are expected to comply with relevant laws and to adhere to the
MARUI GROUP Code of Conduct and internal regulations in their use of social media. Moreover,officers and employees should recognize that it is nearly impossible to completely delete informationfrom the internet after it has been disseminated through social media. Officers and employees should
always act with good common sense in recognition of this fact. Official social media accounts operated
by MARUI GROUP should be used as tools for sincere and appropriate communication based on respect
for the diverse views of stakeholders. Moreover, private social media use, as well as the operation of
official MARUI GROUP social media accounts, should be practiced in compliance with the separately
defined guidelines.

2. Education Regarding Private Social Media Use
In accordance with defined guidelines, MARUI GROUP shall provide regular education regarding
private use of social media in order to facilitate ongoing improvements in awareness among Group
officers and employees.
Social media postings by MARUI GROUP officers and employees on private social media accounts
represent the opinions of the individual that makes the posts. Official announcements and statements by
MARUI GROUP will be issued through MARUI GROUP’s corporate website or through official social
media accounts operated by MARUI GROUP.

3. Official MARUI GROUP Social Media Accounts
MARUI GROUP shall establish guidelines and adhere to the following policies in order to ensure
appropriate use of official social media accounts and facilitate communication with customers.
MARUI GROUP has established standards regarding the opening of official MARUI GROUP social
media accounts, and internal authorization is required to open such an account. Operating official social
media accounts presents the risk of unexpected incidents occurring due to the misinterpretation ofstatements made through these accounts. MARUI GROUP therefore works to ensure that all statements
use appropriate language in consideration of this risk. Postings may be deleted from official social media
accounts should the postings or the language used therein be deemed inappropriate.

Established on June 25, 2018

Revised on March 1, 2022

Basic IT Service Management Policy of MARUI GROUP Subsidiary
M & C SYSTEMS CO., LTD.
IT services have become indispensable to daily business operations, and customer needs pertaining to IT services
are growing increasingly more diverse and sophisticated.
In order to furnish swift and accurate responses to constantly changing customer needs, M & C SYSTEMS must
evolve into a true IT services company in order to provide customers with services that heighten their corporate
value.
Heightening the corporate value of customers requires us to help customers accomplish their business goals by
providing IT services matched to their business and process needs. At M & C SYSTEMS, we recognize that our
raison d’etre is to contribute to the development of customers’ businesses.
Accordingly, M & C SYSTEMS recognizes that its mission is to help improve IT service quality and customer
satisfaction by constantly evolving its IT service management systems.
We go about fulfilling this mission based on the following four basic policies for IT service management
systems.
1. Provision of IT Services Oriented Toward Customers’ Business Goals
In order to ensure that the IT services it provides are oriented toward the accomplishment of customers’
business goals, M & C SYSTEMS optimizes its services based on an accurate understanding of thetechnical requirements of the project as well as on the inherent needs of customers’ businesses.

2. Supply of Services with Increasingly High Levels of Quality
Never satisfied with its present level of service quality, M & C SYSTEMS will pursue ongoing
improvements. Any issues identified with regard to its services will be addressed through concrete
improvement plans.

3. Appropriate Pricing of Services
As it improves the quality of its IT services, M & C SYSTEMS will pursue ongoing cost reductions while
maintaining transparent pricing frameworks to ensure the ideal balance of service robustness andaffordability.

4. Effective Management Processes
M & C SYSTEMS implements effective management processes in relation to the management andoperation of information systems and has in place organizational structures and operational regulations
for supporting the supply of IT services.
Takeshi Ebihara
President and Representative Director, M & C SYSTEMS CO., LTD.
April 2021

MARUI GROUP Procurement Policy
In order to fulfill our social responsibility in the process of manufacturing our products, MARUI GROUP adopts
the attached MARUI GROUP Procurement Policy, which provides concrete practices to be implemented in our
procurement process such as the supply of safe and reliable products and compliance with laws and other rules, aswell as human rights and working environment issues. We will work on compliance with this policy together with
our suppliers engaging in the manufacture of MARUI GROUP products. Our suppliers are also expected topromote the same efforts with their own suppliers.

1. Supply of Safe and Reliable Products– Continuously endeavor to improve the quality of products based on quality control systems.
– Endeavor to ensure the health and safety of product users.

2. Compliance with Laws and Other Rules– Comply with laws, regulations, treaties, industrial standards, and other related international rules
applicable in the countries and areas where business is being conducted (hereinafter “Laws and Other
Rules”).

3. Respect for Human Rights– Refrain from using child labor. Refrain from employing young workers in tasks that are likely tojeopardize their health, safety, or morals.
– Ensure that all employees provide their services voluntarily.
– Refrain from using corporal punishment or other physical or mental coercion or verbal abuse.
– Refrain from discrimination.

4. Establishment of Proper Working Environment– Pay wages and allowances, provide employee welfare benefits, and enter into labor contracts
appropriately.
– Set working hours and provide holidays, vacations, and rest periods in compliance with Laws andOther Rules. Overtime work is to be performed only with employees’ consent and in accordance withstatutory procedures.
– Respect employees’ rights to establish and join organizations and to bargain collectively without
interference or oppression.
– Provide all employees with a safe, healthy, and sanitary working environment including buildings,
facilities, etc.

5. Fair Trade– Engage in business in a fair and proper manner. Providing gifts or entertainment in order to obtain ormaintain an unfair advantage or preference is not allowed.
– Refrain from engaging in an activity which may impede free competition or imposing a one-sided
transaction by abuse of a superior bargaining position.
– Perform import and export transactions appropriately.
– Protect trademark rights, copyrights, patent rights and other intellectual property rights, and respectsuch intellectual property rights of third parties.
– Refrain from engaging in any relationship with anti-social forces.

6. Protection of Information– Appropriately manage confidential information and personal information.

7. Conservation of the Environment– Comply with Laws and Other Rules concerning the environment, and engage in activities to prevent
environmental pollution and to reduce negative impacts on the environment.

8. Contribution to Local Communities– Become involved in and build good relationships with local communities.

9. Establishment and Implementation of Infrastructure for This Policy– Establish infrastructure to implement this policy and share with employees.
– When MARUI GROUP or a representative selected by MARUI GROUP examines suppliers’
compliance of this policy with regard to their factories or offices, the suppliers and MARUI GROUP or
its representative will cooperate with each other.

MARUI GROUP Human Rights Policy
Basic Principles
MARUI GROUP envisions a world in which we have transcended all dichotomies to build a flourishing andinclusive society that offers happiness. The happiness to which we seek to contribute can only be realized
through co-creation with customers, investors, communities and society, business partners, and future
generations. MARUI GROUP views every one of its stakeholders as a partner for co-creating a happier future.
For this reason, we are committed to complying with all international standards and laws pertaining to humanrights as well as with the spirit they embody. Moreover, we faithfully observe the MARUI GROUP Human
Rights Policy, which was established based on the United Nations Guiding Principles on Business and Human
Rights, to ensure respect for the human rights of all people.

1. Dedication to Respecting Human Rights
We stand in opposition of all discrimination, whether on the basis of race, nationality, religion, ideology,
belief, biological sex, age, physical characteristic, gender identity, or sexual orientation, and exercise
respect for the personalities, individuality, and human rights of our customers and everyone else weinteract with through our business activities.

2. Commitment to Compliance with Laws and International Standards
MARUI GROUP complies with laws and international standards regarding human rights. Accordingly,
we adhere to the standards described in the International Bill of Human Rights and the ILO Declaration
on Fundamental Principles and Rights at Work. In cases in which there are disparities between legal
requirements and international standards, we will prioritize conformity to international standards to thegreatest degree possible.

3. Scope of Applicability
The MARUI GROUP Human Rights Policy is applicable to all MARUI GROUP officers and employees.
In addition, requests will be submitted to any supplier, business partner, or other party associated withMARUI GROUP’s business to cease human rights violations in the event that it becomes apparent thatthe actions of such parties constitute violations.

Human Rights Initiatives
1. Human Rights Due Diligence
MARUI GROUP has put in place human rights due diligence frameworks for identifying and assessing
any potential or apparent serious human rights risks. Ongoing measures are implemented to mitigate andprevent the serious human rights risks identified through this framework. Moreover, the framework isperiodically reviewed based on the United Nations Guiding Principles on Business and Human Rights

and steps are taken to adapt it for the contemporary social climate.

2. Corrective Measures (Remedies)
Should it be found that the MARUI GROUP was implicitly or explicitly involved in actions that violated
human rights, appropriate corrective measures will be taken. The effectiveness of corrective measures(remedies) is being enhanced through the establishment of grievance mechanisms.

3. Stakeholder Engagement
MARUI GROUP engages in dialogue and discussion with its various stakeholders on the topic ofpotential human rights risks and corrective measures for addressing violations of human rights in order toimprove the quality of its human rights activities.

4. Human Rights Awareness Improvement
MARUI GROUP is proactive in conducting training for all officers and employees along witheducational activities targeting business partners in order to improve human rights awareness together
with all stakeholders and ensure that the MARUI GROUP Human Rights Policy is effectively observedin all business activities.

5. Human Rights Management
Based on the MARUI GROUP Human Rights Policy, periodic reviews of MARUI GROUP’s initiatives
are performed by the Compliance Promotion Board, which is chaired by the president. The findings ofthese reviews are incorporated into business processes to strengthen management pertaining to humanrights issues. Furthermore, relevant Company divisions, operating companies, and MARUI GROUPUNION coordinate to advance ongoing initiatives for identifying human rights risks and preventing theirmaterialization. In addition, the MARUI GROUP Human Rights Policy is revised on an annual basis.

6. Information Disclosure
MARUI GROUP discloses information pertinent to its human rights initiatives and potential and actual
violations of human rights.

Material Human Rights Issues
Through the process of identifying human rights risks via the use of risk mapping, MARUI GROUP defined thefollowing material human rights issues. These issues will be revised as necessitated by changes in MARUIGROUP’s business or in the social climate.

Respect for Rights of Individuals– Prohibition of all discrimination, whether on the basis of race, nationality, religion, ideology, belief,
biological sex, age, physical characteristic, gender identity, or sexual orientation

Respect for Rights of Workers– Prohibition of forced labor and child labor– Respect for freedom of work style– Prevention of unusually low wages (those that fall below the minimum wage) and provision of a living
wage– Prevention of excessive work hours– Respect for rights to freedom of assembly and collective bargaining– Prohibition of power harassment, sexual harassment, and all other forms of harassment– Promotion of occupational health and safety and health improvement

Respect for rights of vulnerable people affected by business activities and of future generations– Respect for rights of women, children, people with disabilities, senior citizens, low- andmiddle-income individuals, non-Japanese residents of Japan, and other vulnerable people– Respect for rights of future generations

Protection of Privacy– Protection of privacy through safeguarding of personal information of customers, employees, and otherstakeholders

Established in November 2017
Revised in July 2020
Hiroshi Aoi
President and Representative Director
Representative Executive Officer
MARUI GROUP CO., LTD.

MARUI GROUP Customer Engagement Policy
Basic Principles
MARUI GROUP aspires to harness the power of business to build a world that transcends dichotomies in its quest
to contribute to co-creating a flourishing and inclusive society that offers happiness to all. The happiness to which
we seek to contribute can only be realized through co-creation with all of our stakeholders, including customers,
investors, communities and society, business partners, and future generations. MARUI GROUP views thesestakeholders as partners in its quest to co-create happiness. Of particular importance in this regard are customers,
who form the basis for all of the Company’s business activities. One aspect of MARUI GROUP’s corporate
philosophy is to “continue evolving to better aid our customers.” Based on this philosophy, the MARUI GROUP
Customer Engagement Policy has been established to represent our promise to society on how we will engage andrelate to customers.

Scope of Application
This policy is applicable to all MARUI GROUP officers and employees. In addition, all business partners
are asked to act in accordance with this policy.

Legal Compliance and Observance of International Agreements
MARUI GROUP complies with the Basic Act on Consumer Policies and various other customer-related
regulations* as well as with local ordinances and agreements and national laws. In addition, consideration
is paid to Keidanren’s Charter of Corporate Behavior and international agreements, such as the OECD
Guidelines for Multinational Enterprises, the ISO 26000 social responsibility standard, and the United
Nations Sustainable Development Goals, in order to ensure the Company conducts itself in a manner thatis ethical and responsible toward society.
* Laws including the Act against Unjustifiable Premiums and Misleading Representations, theTrademark Act, the Copyright Act, the Product Liability Act, the Money Lending Business Act, theInstallment Sales Act, the Act on Prevention of Transfer of Criminal Proceeds, the Act on Specified
Commercial Transactions, the Act on the Protection of Personal Information, and the Consumer Contract
Act as well as other laws stipulated in internal regulations

Management
MARUI GROUP strives to prevent violations of this policy through appropriate reviews of internal
initiatives by the Board of Directors and the Management Committee based on the policy and throughimprovements to operating processes. Should an issue be detected, it will be reported to the Compliance
Promotion Board through the Information Security Committee, the Safety Control Committee, or anotherrelevant committee. At the same time, swift, effective, and responsible action will be taken to address theissue, and measures will be implemented to prevent recurrence and pursue ongoing improvements after
determining the root cause of the issue.

Furthermore, this policy, related internal regulations, and the MARUI GROUP Quality Standards will
be regularly reviewed, with revisions implemented as deemed necessary after examining the latest
regulations. Revisions to this policy will be communicated to officers, employees, and all other relevant
parties. In addition, a customer consultation venue will be maintained to quickly identify and address
violations of this policy and to heighten the effectiveness of corrective and remedy actions. Grievancemechanisms and whistleblowing systems will also be instituted.

Customer Engagement Enhancement
MARUI GROUP provides timely learning opportunities to all officers and employees for the purpose of
fostering and disseminating the sense of values necessary for the exercise of this policy. Education andtraining programs are also instituted at the appropriate timing to help employees acquire the basic andspecialized knowledge required in their respective lines of business. Moreover, workplace environments,
human resource evaluation systems, and corporate governance systems are shaped and implemented withthe aim of supporting adherence to this policy. Business partners and other parties that interact directlywith customers are also encouraged to take part in training.

Information Disclosure
MARUI GROUP discloses important information needed by customers for the purpose of decision
making in a timely manner on its website or through other media when appropriate. Swift notification andhighly transparent disclosure will be provided in the event of a revision to product or service information,a recall, an information leakage, or a violation of this policy.

Core Themes and Action Policies
Customers form the basis for all of MARUI GROUP’s business activities. Based on the concept of inclusion, weview all stakeholders with which MARUI GROUP connects as customers. MARUI GROUP respects the diversityof all customers throughout every aspect of its lifestyles, including clothing, food, housing, and entertainment, andseeks to provide customers with options for expressing themselves and obtaining happiness and to co-create an
inclusive society together with stakeholders. The following six core themes have been defined to guide these
efforts.

1. Co-Creation with Customers
MARUI GROUP’s unique core value is the co-creation of creditability, which is based on the belief of
MARUI GROUP’s founder that “creditability should be built together with customers.” As times andcustomer values change, MARUI GROUP will continue to engage in co-creation with customers in its
retailing and fintech businesses as well as in new businesses while discussing with customers andincorporating their input.

2. Diversity & Inclusion
As stated in the MARUI GROUP Human Rights Policy, we stand in opposition of all discrimination,
whether on the basis of race, nationality, religion, ideology, belief, age, physical characteristic, gender
identity, sexual orientation, or income level. By incorporating the diversity of all customers into ourbusiness, we seek to accommodate all customers equally with regard to our products, services, store
environments, advertisements, websites, social media, and customer service.

3. Provision of Options for Realizing a Sustainable Society
Together with stakeholders, MARUI GROUP endeavors to co-create products and services that generateearnings while addressing social issues pertaining to the reduction of environmental impacts and respectfor human rights. Moreover, we provide diverse sustainable options with consideration paid to customer
health as well as to the environment, human rights, community outreach, and animal welfare.

4. Customer Safety and Security
MARUI GROUP complies with relevant laws, ordinances, and internal regulations at all customer
contact points in order to ensure that the products and services it supplies are safe and secure forcustomers. In addition, we support customer decision making by providing customers with the necessary
information with regard to sales and contracts.
MARUI GROUP also has frameworks in place to cancel contracts or institute recalls as appropriate
when risks have been detected or when serious deficiencies have been identified after the conclusion of asale or contract. Furthermore, after-sales services are offered through information provision at stores andEPOS customer service centers and on the websites of Group companies.

5. Responsible Marketing and Communication
MARUI GROUP avoids unfair, false, or misleading marketing, expressions, or displays in its products,
services, store environments, advertisements, websites, social media, and customer service and all of its
other contact points with customers. We also refrain from using discriminatory or offensive expressions,speech, or images while conducting responsible corporate activities with consideration exercised forchildren and others in vulnerable social positions. Relevant divisions are responsible for confirming theappropriateness of the details, expressions, and utilization practices of marketing and communications.
Moreover, we respect the right of consumers to receive education described in the Basic Act on
Consumer Policies and conduct information disclosure and educational activities accordingly.
MARUI GROUP will not provide misinformation about the products and services of other companies
for the purpose of damaging the reputation of those companies in any of its customer contact points.

Segment Initiatives Pertaining to 4. Customer Safety and Security and 5. Responsible
Marketing and Communication

1. Retailing Segment
・ Compliance with the internal, legally based MARUI GROUP Quality Standards in the planning of private
brand products
・ Development of store environments and use of store facilities that accommodate multiple languages andutilize universal design principles
・ Twice-annual fire drills and once-annual disaster drills at stores to foster high levels of disaster preparedness
among employees and tenants・ Consideration for disparities between product representations and actual products on online sales websites andprovision of easy-to-understand procedures for product returns and exchanges

2. FinTech Segment
・ Compliance with laws and regulations, such as the Act on the Protection of Personal Information, theInstallment Sales Act, the Money Lending Business Act, and the Financial Instruments and Exchange Act, as
well as with social ethics and MARUI GROUP’s corporate philosophy and codes of conduct in EPOS card
applications and financial product contracts (credit card contracts, cash advances, securities, etc.)
・ Appropriate setting and management of credit limits based on customer usage patterns
・ Provision of services that offer choices with regard to repayment amounts and timing
・ Appropriate responses to fraudulent credit card use that goes against customer intent and provision of credit
card use notification services, online use information protection services, and other services offering peace ofmind
・ Protection of customer assets and appropriate information provision to ensure the safety and security ofservices
・ Establishment of and compliance with solicitation policies based on the Act on Sales, etc. of Financial
Instruments in securities and insurance businesses

6. Customer Information Management
MARUI GROUP will collect personal information from customers for the purpose of providing highly
satisfying services as stated in the MARUI GROUP Information Security Policy, the MARUI GROUP
Privacy Policy, the Privacy Policy of MARUI GROUP CO., LTD., and the MARUI GROUP Social
Media Policy. The personal information of customers is viewed as an important asset for fueling theongoing growth of the Company, and we recognize that appropriate management of this information is an
important responsibility of management.
MARUI GROUP shall respond to any inquiries regarding the disclosure, revision, or deletion of
personal information as well as any complaints or consultations from individuals or proxies acting on
behalf of individuals pertaining to personal information it has collected. Steps are taken to improveGroupwide information security and management precision to protect the personal information ofcustomers and other information assets held by MARUI GROUP from unauthorized access, cyber attacks,and various other threats. These efforts are spearheaded by the Information Security Committee, which
comprises directors and executive officers.

Established in March 2021
Hiroshi Aoi
President and Representative Director
Representative Executive Officer, CEOMARUI GROUP Occupational Health and Safety Policy
MARUI GROUP seeks to co-create customer happiness through its business activities, which merge retailing andfinance. We understand that providing employees with a safe and hygienic workplace environment is essential tosupporting the growth of all employees and is instrumental to invigorating the entire organization and driving theimprovement of corporate value. MARUI GROUP therefore declares its intent to act in accordance with thisunderstanding in all business activities, pursue higher levels of safety and hygiene, and to promote voluntary
occupational health and safety initiatives on a Groupwide basis.

1. Development of a Workplace Environment that Prioritizes Health and Safety
Realizing that the health and safety of employees is crucial to their growth, all workplaces will foster
awareness and heighten understanding regarding occupational health and safety, prioritizing thedevelopment of an environment in which employees can feel safe and secure and maintain good mental
and physical health as they work.

2. Promotion of Voluntary Occupational Health and Safety Initiatives
Occupational health and safety targets are set at all Group companies and workplaces based on MARUIGROUP’s occupational health and safety plans in order to promote voluntary occupational health andsafety initiatives. These targets are periodically revised to pursue higher levels of health and safety on aGroupwide basis.

3. Compliance with Occupational Health and Safety Laws
We comply with Japan’s Industrial Safety and Health Act and other labor-related legislation as well aswith the internal rules regarding occupational health and safety in place at all Group companies andworkplaces.

4. Realization of Safe and Low-Risk Workplace Environments
MARUI GROUP seeks to realize safe and low-risk workplace environments by determining the sourcesand extent of the occupational accident risks faced in each business and formulating and implementing
measures to reduce or eliminate these risks.

5. Facilitation of Employee Health Improvement
MARUI GROUP understands that the health of employees is crucial to their growth. We therefore
practice healthcare management aimed at preventing mental health issues and lifestyle diseases as well as
enabling all employees to feel more energized in their work.

6. Cultivation of a Corporate Culture Emphasizing Occupational Health and Safety
We will cultivate a corporate culture emphasizing occupational health and safety by conducting proactive
employee education and awareness-raising programs related to these topics. All Group officers andemployees are expected to observe the MARUI GROUP Occupational Health and Safety Policy, and we
ask that business partners and other external stakeholders endorse this policy while also making thispolicy publicly available.

Occupational Health and Safety Management System

Healthcare Management Promotion System
MARUI GROUP practices healthcare management to prevent mental health issues and lifestyle diseases
in employees, limit exposure to secondhand smoke, reduce overtime, and raise employee healthawareness. Healthcare management initiatives are spearheaded by MARUI GROUP’s Personnel Division
and Wellbeing Promotion Department and are coordinated with the Company’s health insurance union.

Consultation Venues
Company physicians and occupational health staff are positioned in MARUI GROUP’s Wellbeing
Promotion Department on a full-time basis to provide employees with a venue for consulting on mental
health and other health issues and for receiving support in improving lifestyle diseases. In addition, wehave established a hotline for receiving third-party physical and mental health consultation throughcollaboration with a specialized external organization.

Hiroshi Aoi
President and Representative Director
Representative Executive Officer
MARUI GROUP CO., LTD.
April 30, 2021

MARUI GROUP Human Resource Development Policy
Basic Principles
MARUI GROUP’s corporate philosophy calls on us to “continue evolving to better aid our customers” and “equate
the development of our people with the development of our company,” and MARUI GROUP has defined its
mission as being to “contribute to co-creating a flourishing and inclusive society that offers happiness to all.”MARUI GROUP views employees as a precious asset borrowed from society. Based on this belief, the Company
is committed to stimulating the growth of employees in order to fulfill its role as a venue for the contributions of all
employees and as a member of the communities it serves and of the greater society.
Moreover, MARUI GROUP has defined the two characteristics it desires in employees. One of thesecharacteristics is the capacity for empathy needed to adopt the viewpoints of various stakeholders in order tounderstand their thinking and their pain. This capacity for empathy gives rise to a propensity for innovation, thesecond of these characteristics, that drives the resolution of social issues through business activities.
To accomplish these goals, MARUI GROUP seeks to facilitate diverse work styles as well as the careerdevelopment efforts of employees while encouraging mutual understanding between all employees, regardless of
their age, nationality, physical characteristics, gender identity, and sexual orientation. Through this process, we aim
to generate innovation while supporting the contributions and growth of diverse employees. Furthermore, we areworking to help all employees grow into talented human resources who gain insight and broaden their horizons
through self-driven learning and who assess situations from an altruistic perspective. This approach will be
imperative in ensuring that MARUI GROUP can continue to contribute to society.
MARUI GROUP will continue to translate individual strengths into organizational capabilities as it exercises its
corporate philosophy going forward.

Desired Characteristics in Employees
MARUI GROUP has defined the following characteristics as the characteristics desired in employees.

Human Resource Development Frameworks
MARUI GROUP proactively conducts human resource investments based on the belief that human resources areintangible assets that are a wellspring of future corporate value.
All MARUI GROUP employees are hired through the Company, which is a pure holding company, and thenappointed to Group companies while being given access to the same shared human resource systems and working
under the same wage and workhour standards.
The growth of employees is stimulated through profession change, secondment, and evaluation systems as well asother frameworks based on voluntary participation.* We are heightening the effectiveness of these frameworks with
an emphasis on the development of energized and empowered employees that are accepting of one anotherregardless of their age, nationality, physical characteristics, gender identity, and sexual orientation along withorganizations that support these employees.

1-1. Voluntary Participation*
MARUI GROUP aspires to be a company that can continue to generate innovation. Accomplishing thisobjective will require that our business be based on autonomous organizations, which we believe will
foster autonomous employees. For this reason, we encourage employees to tackle new challenges on a
voluntary basis in order to cultivate a sense of autonomy. We offer opportunities that encourage
wide-ranging voluntary participation* and include forums for discussions on important management
themes as well as various learning and new business creation opportunities and the intra-Group
profession system.
* All MARUI GROUP employees are provided with access to opportunities in which they can participate
on a voluntary basis through open application.

1-2. Intra-Group Profession Changes and Secondment
MARUI GROUP offers an intra-Group profession change system that allows for relocations between
Group companies as a framework for fostering individual diversity and driving organizational reforms.
We are confident that tying the discoveries of individuals to organizational reforms and business
innovation will support the exercise of MARUI GROUP’s corporate philosophy.
In addition, MARUI GROUP employees are seconded to investees and other start-up companies toendow them with the scope of vision needed to create new businesses from a forward-looking perspective
and to provide them with various opportunities to exercise discretion in decision making. The resulting
merging of different insights is anticipated to fuel open innovation.

1-3. Evaluations, Feedback, and Progress Monitoring
MARUI GROUP has developed human resource evaluation systems based on a medium-to-long-term
perspective with the aim of linking the growth of individual employees to the ongoing growth of theCompany. Under these systems, human resource evaluations comprise value evaluations and performanceevaluations. The former assesses employees’ abilities to take autonomous action and pursue individual
growth based on MARUI GROUP’s corporate philosophy and is determined by evaluation committees
based on 360-degree evaluations from team members. The latter evaluates team performance over a given
period. In addition, employees in all departments meet with their supervisors on a quarterly basis tomonitor their progress and on a six-month basis to receive feedback. These meetings are meant to serve
as opportunities for confirming individual challenges and the types of improvements that should be
pursued. Through such initiatives, MARUI GROUP provides opportunities for discoveries and learningin order to drive individual growth.

1-4. Promotion Practices
MARUI GROUP actively promotes to leadership positions individuals who consistently exhibit thenecessary qualities and skills and who contribute to improvements in corporate value. These promotions
are performed in a fair and equal manner that is not influenced by factors such as age, gender identity,
nationality, or career background.

1-5. Future Leader Development Program
MARUI GROUP has implemented a future leader development program based on open application. Aftercompleting the one-year program, participants are seconded to affiliates or positioned to strategic or
corporate planning divisions to endow them with the scope of vision needed to create new businesses
from a forward-looking perspective and to provide them with various opportunities to exercise discretionin decision making in order to further their growth as future leaders.

2. Management System
MARUI GROUP is enhancing its management of human resource development through appropriate
reviews of internal initiatives by the Board of Directors and the Management Committee and throughreflection of these reviews in work processes based on the MARUI GROUP Human Resource
Development Policy. Moreover, coordination is pursued between relevant MARUI GROUP divisions,operating companies, and MARUI GROUP UNION to confirm the progress and effectiveness of
initiatives related to human resource system and organizational reforms. Moreover, the MARUI GROUP
Human Resource Development Policy will be reviewed annually, and timely and appropriate disclosure
will be practiced with regard to internal awareness-building initiatives, targets, and related progress.

Established in March 2021
Hiroshi Aoi
President and Representative Director
Representative Executive Officer, CEOMARUI GROUP CO., LTD.

MARUI GROUP Environmental Policy
Basic Policy
MARUI GROUP CO., LTD., is promoting green businesses, which provide options for coexistence with the global
environment, as described in MARUI GROUP’s 2050 Vision, its long-term vision. This undertaking is prefaced on
our belief that helping build a sustainable society and global environment through our business is part of our ethicalresponsibility toward future generations.
We recognize the importance of implementing PDCA (plan–do–check–act) cycles to manage our efforts to reduce
environmental impacts while generating profits. Based on this recognition, MARUI GROUP has laid out a clear
basic policy and defined priority issues and action policies.

1. Environmental Management
At MARUI GROUP, deliberation and decisions regarding initiatives for addressing environmental issues
as well as the execution of these initiatives are carried out by the Sustainability Committee, an advisory
body to the Board of Directors chaired by the president and representative director, and the Environment
and CSR Committee, an organization established under the Sustainability Committee for carrying out
related procedures. Ongoing management of these initiatives is practiced through the implementation of
PDCA cycles. In addition, coordination is pursued with divisions related to energy, resources, products,
tenant development and management, and sustainability in advancing initiatives for addressing
environmental issues. Furthermore, steps are taken to strengthen governance pertaining to environmental
management through reports and proposals to the Board of Directors and the MARUI GROUP
Environmental Policy is reviewed on an annual basis.

2. Legal Compliance
MARUI GROUP complies with environmental legislation, regional ordinances and agreements, the lawsof relevant countries, and international environmental standards. Emphasis is also placed on abiding withinternational agreements, such as the United Nations Sustainable Development Goals.

3. Environmental Due Diligence
The priority issues that MARUI GROUP will need to tackle going forward cannot be surmounted by theGroup alone. Rather, overcoming these challenges will require co-creation with all of MARUI GROUP’s
stakeholders and across its value chain. Recognizing this fact, MARUI GROUP practices environmental
due diligence through a process of accurately identifying material environmental risks, issuing reports,
pursuing improvements, and monitoring progress. Input from various stakeholders is utilized throughout
this process.

4. Stakeholder Engagement
MARUI GROUP has defined its mission as promoting harmony and the expansion of the intersection

between the interests (happiness) of six groups of stakeholders—customers, investors, business partners,
communities and society, employees, and future generations. Accordingly, MARUI GROUP isincorporating feedback from and stepping up engagement with various stakeholders in its quest toaddress environmental issues through co-creation.

5. Environmental Awareness Improvement
MARUI GROUP aspires to improve environmental awareness through joint efforts with various
stakeholders. Specific examples of such efforts include training for Group officers and employees aimed
at facilitating the understanding and dissemination of environmental issues and the MARUI GROUP
Environmental Policy and promoting related actions as well as communication activities aimed atcustomers and business partners.

6. Transparent Environmental Information Disclosure
MARUI GROUP conducts environmental information disclosure based on the recommendations of the
Task Force on Climate-related Financial Disclosures and other international information disclosure
standards. Periodic disclosure regarding environmental activities, their results, and the impacts on the
Company’s finances is conducted, third-party verification is received, and transparency is ensured.

Priority Issues and Action Policies
1. Climate Change
Climate change is an issue that threatens the very survival of the human race. In fact, this phenomenon
has come to be referred to as a climate crisis. To address and help mitigate climate change based on theconsensus laid out in the Paris Agreement, MARUI GROUP is implementing new measures, participating
in international initiatives, promoting action across the supply chain, and taking other steps to realize acarbon-negative status.

Reduction of Greenhouse Gas Emissions
MARUI GROUP is engaged in energy conservation and renewable energy initiatives as part of its efforts
to reduce greenhouse gas emissions. We consistently calculate the volume of emissions from MARUIGROUP and from across its value chain while pursuing emissions reduction goals that have beencertified by the international initiative Science Based Targets to help keep the average global temperature
below 1.5°C above pre-industrial levels.

Energy Conservation
MARUI GROUP is working to conserve energy through co-creation with stakeholders. For example, it isinstalling energy-efficient equipment in stores and offices, implementing other electricity-saving
initiatives, cutting overtime hours through work style reforms, promoting green buildings, recruitingtenants dedicated to reducing environmental impacts, and encouraging business partners to conserve
energy.

Renewable Energy Utilization
As a member of the RE100 initiative, MARUI GROUP aims to source 100% of its electricity fromrenewable energy. To this end, we are introducing renewable energy at Group stores and offices to movetoward the accomplishment of our medium-to-long-term targets. In addition, we encourage customers toswitch to electricity generated from renewable sources in order to propose fulfilling yet ecologicallysound lifestyles.

2. Resource Recycling
MARUI GROUP is promoting resource recycling across its value chain, at steps including production,
distribution, and product use, to preserve the planet’s finite resources. Through co-creation withcustomers, business partners, and other stakeholders, we are promoting effective resource use, reducing
waste, and combating pollution through proper chemical management with the goal of contributing to therealization of a sustainable, recycling-oriented society.

Waste Reduction
MARUI GROUP recognizes that it has a responsibility to reduce waste from its own activities as well as
throughout its value chain spanning from material procurement to manufacturing, product sales, andproduct disposal. Accordingly, we are promoting the 3Rs (reduce, reuse, and recycle) and urging business
partners to refrain from engaging in excessive production and cut back on their use of disposable items.

Sustainable Product Development
MARUI GROUP is developing recyclable products while utilizing biodegradable plastic and biologicaland renewable materials. In addition, we take part in co-creation with business partners in a supply
chain-wide drive to deliver sustainable products and services through the reduction of environmental
impacts, proper management of chemical substances, and other means.

Proper Waste Disposal
MARUI GROUP furnishes systems for disposing of food, industrial, and other waste, and we arepromoting proper waste disposal for purposes such as preventing pollution. We also ask tenants andothers at our business sites to properly sort waste in an effort to improve recycling rates.

Reduction of Container- and Packaging-Related Environmental Impacts
MARUI GROUP is transitioning to more eco-friendly materials for the shopping bags, gift wrapping, andother containers and packaging used in its stores and e-commerce operations with the goal of reducing
the amount of plastic waste produced throughout society. We are also acquiring environmental

certifications in this regard. At the same time, we encourage tenants to reexamine the materials used fortheir shopping bags and product packages.

Reduction of Food Loss and Waste
Together with its customers and business partners, MARUI GROUP endeavors to reduce food waste bypromoting smaller portions and pre-ordering for food items. Moreover, food waste is rigorously sorted atbusiness sites to improve recycling rates.

Water Resource Management
MARUI GROUP manages water resources with the goal of minimizing water pollution and emissions ofhazardous chemicals and reducing its water consumption. We also encourage business partners and otherassociates across the supply chain to act in accordance with our CSR procurement policies in order toprevent water pollution along with the use of hazardous chemicals in product manufacturing activities.

3. Preservation of Sustainable Ecosystems
Our lives and economic activities are built on the natural blessings bestowed upon us by sustainableecosystems. MARUI GROUP seeks to help preserve sustainable ecosystems through co-creation with its
stakeholders. We are thus exercising consideration for biodiversity and engaging in CSR procurementwith responsible suppliers.

Sustainable Procurement
MARUI GROUP approaches business partners to promote responsible and sustainable procurement
across the supply chain and thereby ensure that it is able to supply customers with safe and secure
products. We are committed to the appropriate procurement and use of materials and foods, goals we are
pursuing by selecting organic materials subject to management of chemical substances and by taking
precautions regarding animal welfare and the sustainability of production regions. In addition, MARUIGROUP aims to improve the reliability of its traceability measures.

Harmony with Nature
MARUI GROUP engages in co-creation with local communities for the purpose of preserving healthy
ecosystems. This co-creation takes forms such as store and greenery development measures that areconsiderate of biodiversity and initiatives for combating the urban heat island phenomenon. Meanwhile,
co-creation is pursued with customers to promote harmony with nature through means such as providing
customers with opportunities and venues for engaging with nature.

Segment Initiatives
MARUI GROUP is advancing the following segment initiatives based on the aforementioned priority issues andaction policies.

1. Retailing Segment

Store Initiatives– Promote energy conservation and renewable energy use– Coordinate with tenants in waste reduction, water conservation, recycling, and other initiatives– Transition to new packaging and container materials, utilize electronic receipts, and advance otherresource conservation initiatives– Reduce food waste through smaller portions and pre-orders for food products– Utilize sustainable materials for facility interiors and exteriors– Recruit experience-providing, direct-to-consumer, and other tenantsOmni-Channel Retailing Initiatives– Expand order pickup sites to limit need for re-delivery– Practice cyclical distribution between bases and other eco-friendly distribution activities– Reduce environmental impacts by reviewing packaging and container materials

Product and Service Development– Develop eco-friendly products and services through co-creation with customers– Reduce waste by providing products matched to customer needs– Create business models compatible with circular economies

2. FinTech Segment

Credit Card Initiatives– Develop credit card surfaces using low-environmental impact materials– Conserve resources through electronic billing statements, etc.

Environmental Awareness Initiatives Targeting Cardholders– Propose switch to electricity from renewable sources– Provide options to use points for donations to environmental NPOs, etc.

3. New Businesses

Eco-Friendly Product and Service Development– Develop new products using renewable materials– Practice sustainable procurement through traceability of materials and food products, etc.
– Utilize materials with environmental certifications

Proposal of Ecologically Sound Lifestyles– Create businesses attuned to new values– Propose new, eco-friendly food options– Offer eco-friendly living proposals

Established in 2008
Revised in November 2016
Revised in April 2020

MARUI GROUP Director Compensation Determination Policy
1. Basic Policy
Compensation for directors shall be linked to shareholder interests in order to provide sufficientincentive for pursuing medium-to-long-term improvements in corporate value.
Compensation for directors (excluding external directors and directors who do not reside inJapan) comprises fixed basic compensation as well as performance-linked bonuses, which are based on
the performance of the Company in a given fiscal year to function as a short-term incentive, andperformance-linked stock-based compensation, which is based on the medium-to-long-term
performance of the Company to function as a medium-to-long-term incentive.
Benchmarks for compensation levels and the ratios of compensation are set based on the officer
compensation levels and the ratios of compensation of companies of a similar scale to MARUIGROUP as determined using data from officer compensation surveys conducted by external researchfirms. The Company’s compensation levels and ratios are measured against these benchmarks eachyear.
External directors will only receive fixed basic compensation based on their position to ensurethat they maintain an independent standpoint.

2. Policies for Determining Amounts of Fixed Basic Compensation Paid to Individual Directors(Including Policies for Deciding Payment Timing and Conditions)
Basic compensation shall be paid to directors as a fixed amount on a monthly basis in accordance withthe payment conditions determined for each director rank by the Nominating and Compensation
Committee in line with the basic policy described in 1. above.

3. Policies for Determining Amounts and Calculation Methods for Variable Compensation (Bonuses andStock Compensation) Paid to Individual Directors (Including Policies for Determining Performance
Indicators, Amounts Linked to Specific Indicators, and Payment Timing and Conditions)・Performance-linked bonuses
Performance-linked bonuses are decided in accordance with the duties of each director and with thegoal of increasing motivation for improving performance on a single fiscal year basis.
Performance-linked coefficients are set based on the degree of accomplishment of targets for Company
performance indicators in a given fiscal year, and these coefficients are multiplied by the standard
amount of compensation defined for each rank.
・Performance-linked stock-based compensation
The Company employs a Board Incentive Plan Trust scheme in which a trust fund established throughpayments by the Company is used to issue shares of the Company’s stock to directors.
To increase motivation to contribute to improved medium-to-long-term performance andcorporate value for the Company, the period for the scheme is set to coincide with the Company’s
medium-term management plan, and performance-linked coefficients are determined based on the
degree of accomplishment of the targets for Company performance indicators in the final year of thisperiod. Directors are awarded points based on the performance-linked coefficients, and shares areallocated to each director in an amount that coincides with their aggregate number of points. Directors
will only receive shares of the Company’s stock equivalent to a portion of the number of points
awarded. The value of remaining shares of the Company’s stock will be appraised by the trust anddirectors will be paid a monetary amount equivalent to the appraisal value of said shares.
Shares awarded for the fiscal years ended March 31, 2020 and 2021, the first period for the
Board Incentive Plan Trust scheme, will be subject to a transfer restriction period of one year from thedate of allocation. Should the trust be continued for a period extended beyond the initially planned
period, the period will be extended by a number of years equivalent to the remaining period of thecurrent medium-term management plan and an additional two-year period will be established, andshares awarded for this period will also be subject to a transfer restriction period of one year from thedate of allocation.
・Performance indicators
Performance indicators for performance-linked bonuses and performance-linked stock-based
compensation are decided in conjunction with the formulation of medium-term management plans tocoincide with the objectives of the given plan and are adjusted as necessary based on the changes in theoperating environment by the Board of Directors.
・Performance-linked bonus payment timing
Performance-linked bonuses for a given fiscal year are paid at a predetermined time during thefollowing fiscal year.
・Performance-linked stock-based compensation payment timing
Directors that fulfill the requirements for allocations of shares will receive allocations of shares of theCompany’s stock in an amount equivalent to the allocated points, in principle, in June or later after theconclusion of the final year of the allocation scheme period.

4. Policy for Determining Ratios of Compensation Paid to Individual Directors
The ratios of compensation paid to individual directors are decided by the Board of Directors based on
discussion with the Nominating and Compensation Committee in accordance with the basic policy
described in 1. above.

5. Policy for Deciding the Amounts of Compensation Paid to Individual Directors
Amounts of compensation paid to individual directors are determined by the Nominating andCompensation Committee based on authority delegated by the Board of Directors in order to ensure
the transparency and objectivity of the process of deliberating on compensation.
The Nominating and Compensation Committee is to consist of at least three members, two or
more of whom should, in principle, be external directors. Members shall be decided by resolution of
the Board of Directors.
The Nominating and Compensation Committee shall discuss and decide on the following
matters, while adhering to the scope of the compensation systems and limits approved by the Ordinary
General Meeting of Shareholders, based on comprehensive consideration of factors including thedegree of responsibility for MARUI GROUP’s management and the progress toward the targets of themedium-term management plan.
・Matters regarding payments of compensation to individual directors
・Matters regarding changes to compensation systems for directors
・Other matters for which consultation has been received or authority has been delegated from theBoard of Directors

6. Other Important Matters Regarding Payments of Compensation to Individual Directors
MARUI GROUP has instituted provisions that will enable it to seize the beneficiary rights of shares of
the Company’s stock to be allocated (malus) or to demand restitution in the form of monetary
payments equivalent to the value of allocated shares (clawback) should an applicable director be foundto have engaged in serious misconduct or legal violations.