(Translation)

April 27, 2018

Summary of Investigation Report

To: Japan Emergency NGO (JEN)
President Keiko Kiyama

Japan Emergency NGO (JEN) Special Investigation Committee

Committee Members
Chairman

Attorney-at-law

Ryo Kotoura

Members

Certified Public Accountant Satoko Suzuki
Vice President/Non-Executive Trustee of JEN andAttorney-at-law

Tokuji Nishitani

Auditor for JEN

Yasuhiro Nishi

Japan Emergency NGO (hereinafter “JEN”) began investigating the operational situation inJordan after it received several whistleblowing complaints from several employees and former
employees of JEN, especially pertaining to allegations of misuse of funds at JEN’s Jordan Office(hereinafter “Jordan Office”). During the investigation, some suspicious and wrongful activities
were found to have been carried out, and therefore the board of trustees of JEN decided to call inexternal experts and formed a Special Investigation Committee (hereinafter the “SIC”) to conduct
the investigation on March 1, 2018.
Based on the aforementioned instructions, the SIC conducted its investigation on the alleged
suspicious wrongful activities from March 1, 2018 to April 26, 2018 and submitted its investigation
report on its investigations and findings to the board of trustees of JEN.
This summary of the investigation report (hereinafter the “Summary”) briefly describes theessence of the aforementioned investigation report submitted by the SIC. However, among themisconducts described in the investigation report which are found or likely to be found to have adetrimental impact on JEN, matters on which JEN is still continuing its investigation to further
clarify the details and the staff involved in such misconducts as of the date of the Summary are notincluded in the Summary.

1. Outline of the investigation(1) Outline of the SIC’s investigation
The members of the SIC and its assistants are described below. The SIC is not an external
committee and although it observes the principles of the “Guidelines for Independent Investigation
Committees for Corporate Misconducts” of the Japan Federation of Bar Associations, theinvestigation was not entirely carried out in accordance with such guidelines.

Attorney-at-law (Anderson Mori & Tomotsune). He has extensive
Chairman Ryo
Kotouraknowledge and experience advising on corporate legal affairs, conducting
corporate investigations and understanding on corporate affairs foremerging countries. He is the representing lawyer for JEN. Apart fromthis case, he has never advised or worked for JEN in the past.
Certified public accountant (Satoko Suzuki Accounting Office). She has

Member Satoko
Suzukiconsiderable knowledge in accounting matters of non-governmentalorganizations and extensive knowledge and experience on accounting
audit. Apart from this case, she has never advised or worked for JEN inthe past.

Member Tokuji

Attorney-at-law(EbashiandSuzukiLawFirm),

ViceNishitani

President/Non-Executive Trustee of JEN. He has intensive knowledge
regarding JEN’s internal affairs and is appointed as the administrative
director of a general incorporated foundation.
Certified public accountant (Nishi Accounting Office) and JEN’s auditor.

Member Yasuhiro

He has intensive knowledge regarding JEN’s internal affairs and isNishi

appointed as the auditor of a company listed in the first section of theTokyo Stock Exchange.

Assistant to the investigation

Major roles

Anderson Mori & Tomotsune

general assistance in investigation and legal advice

Hitoshi Matsufuji Accounting Officeadvisor from the perspective of accounting andinvestigation for corporate misconducts

Eversheds Sutherland (Law firm in Jordan)

assistance in investigation and legal advice in The
Hashemite

KingdomofJordan(hereinafter“Jordan” )Precise Business Consulting (Accounting firm

assistance in accounting and investigation forin Jordan)

corporate misconducts

FRONTEO, Inc.

assistance in forensic investigation in Japan

Ernst & Young (EY) Jordan

assistance in forensic investigation in Jordan(2) Purpose, method and scope of the investigation
The following three matters were entrusted to the SIC from the board of trustees of JEN:(a) whether the usage of funds by the Jordan Office from 2012 was appropriate;(b) whether JEN’s governance on these matters was effective and functional; and(c) any other matters the SIC found to be necessary to investigate.
From March 1, 2018 to April 26, 2018, the SIC carried out its investigation within the scope of
the aforementioned matters and other relative matters which were reasonably considered to bewithin such scope. The investigation was limited to (i) verifying the matters where reasonablesuspicion arose from whistle-blowing and preliminary investigations and (ii) investigating theexecution of project budget regarding past funds. The investigation involved in addition toreviewing disclosed materials from JEN (including emails, data, vouchers and others obtained
from forensic investigation), interviewing more than 20 personnel including all members of theboard of trustees (excluding the SIC Member Nishitani), employees (including former employees),
as well as other affiliated personnel.

2. Result of investigation

Pursuant to the investigation carried out, the SIC confirmed that there were multiple misconductsthat were committed at the Jordan Office and the same have been explained in detail below.

Outline of misconducts during the operation(1) Usage of funds that was beyond the scope of its intended purpose
JEN had received funds from Japan Platform (hereinafter “JPF”) specifically for the purposeof supplying water and a hygienic environment and for learning improvement projects for
Syrian refugees in Jordan. However, it was discovered that by the sole discretion of the Head ofMission at the Jordan Office, a building equivalent to a movie theater (construction cost being
approximately JPY 9.2 million) was being constructed within the Syrian refugee camp inJordan. The construction of such a building was for recreational purposes and to provide
informal educational opportunities to Syrian refugees, which was beyond the scope of theintended usage of the funds that was originally approved by JPF (i.e. developing and repairing
water and sanitation facilities).
(2)

Handling of off-the-book cash
It was confirmed that the safe deposit vaults at the Jordan Office had cash which wasunaccounted for in the books of accounts. It is not clear if the source of such off-the-book cash
was from funds for other projects or the personal fund of the Head of Mission at the Jordan
Office, but it can be acknowledged that this off-the-book cash had been in the vaults of theJordan Office since 2013 at least. As of April 24, 2018, the total amount of the off-the-bookcash was about JPY 750,000.

(3)Transactions made against internal procurement rules
At the Jordan Office, even though there was a rule that JEN employees could not let theirfamily or relatives or the like be involved in any procurement activities for JEN, it wasdiscovered that an employee of JEN who was in charge of procurement at the Jordan Office hadentered into and executed an agreement for procurement of services with a company whose
shareholder and representative was a family member of that employee of JEN. The amount ofdamage JEN suffered would be the difference between the price actually paid for such services
procured and the market price of such service. Since it was difficult to confirm the market priceof the service during the time period when such service was procured, JEN’s damage from such
violation could not be calculated.

3. Issues in governance (root cause)First, we found that the root cause of the misconducts is absence of effective governance within
and toward Jordan Office, including lack of proper control and insufficient internal monitoring on
the Jordan Office and lack of proper and smooth communication, which can be called as insulationof information, between the Jordan Office and the Tokyo headquarters of JEN.
Second, as a so-called ‘accredited NPO’, JEN is socially expected to conduct its activities inpublic interest in a more responsible and fair manner compared to other regular NPOs. Moreover,since its activities have been supported by donations and institutional funds, JEN should have
performed its duties through its employees with a stronger sense of responsibility as a trustee of such
donation and institutional funds.
Although the objectives of JEN to support refugees and internally displaced persons as well as
disaster survivors was acknowledged and a sense of achieving their mission was shared at JEN, they
lacked the sense of strong responsibility that they are the ones entrusted with donations and publicfunds.

In other words, JEN and its employees lacked of the compliance consciousness forunderstanding of the code of conducts and regulations, having sense of complying with the internal
protocol and fulfilling compliance requirements in the course of implementation of the projects.

4. Proposed measures for recurrence prevention
Taking into consideration such circumstances, SIC proposes the following measures to prevent
recurrence of any future misconduct in operation and for JEN to restart anew as an organization witheffective governance and controls desirable for an accredited NPO:(i)sharing amongst the employees of JEN with a strong sense of responsibility as a trustee ofthe donation and institutional funds by individuals and institutions;(ii)

reviewing an appointment term of the Head of Mission of overseas office, such as
introducing personnel rotations (fixed-term appointment) and abolition of double-hattingof Head of Mission of overseas office and Director of Global Program Department ofTokyo headquarter office by one person;(iii)

clarifying the roles and responsibility of members of the board of trustees at the Tokyo
headquarters and optimizing the central control system; and(iv)continuing the investigation and implementing improvement plans for JEN to pursue.