The MEDIA DO Group (comprised of MEDIA DO Co., Ltd., and its consolidated subsidiaries) recognizes that compliance is an important management priority. All officers and employees are expected to remain mindful of the Group’s social responsibilities in their actions, and we are committed to maintaining the trust of our employees, business partners, shareholders, and other stakeholders through compliance with relevant laws and regulations in accordance with the Basic Compliance Policy.

Decisions regarding the amendment or abolishment of this policy are to be made based on resolution by the Board of Directors.

1. Basic Policies

(1) The MEDIA DO Group will practice stringent legal compliance and adhere to high standards of corporate ethics throughout its business activities in order to achieve ongoing growth and enact its corporate philosophy while fulfilling its social responsibilities.

(2) Compliance at the MEDIA DO Group includes observing the requirements stipulated by all laws, regulations, Group rules and manuals, and social norms applicable to the Group’s business activities and conducting corporate activities in a fair, impartial, and earnest manner that is based on high standards of corporate ethics.

2. Compliance Promotion System

(1) Overview of System

  1. The Company’s compliance promotion system shall require appropriate reporting of important compliance-related matters to management.
  2. A compliance representative shall be appointed to promote compliance and manage compliance-related information in a centralized manner, and authority shall be delegated to this representative as necessary to ensure sufficient compliance.
  3. Frameworks shall be put in place to allow officers and employees to report or receive consultation should they become aware of compliance issues.

(2) Compliance Promotion Measures

  1. Awareness regarding the established Action Guidelines for Compliance shall be promoted in order to facilitate the practice of compliance.
  2. Regular compliance training shall be held.
  3. Compliance representatives shall conduct regular inspections to ensure thorough compliance.
  4. Swift action shall be taken to remedy compliance issues, and the cause of issues shall be analyzed to prevent reoccurrence.

3. Compliance Guidelines for Officers and Employees

  1. Officers and employees shall carry out their duties in an earnest, fair, and appropriate manner in accordance with the basic principle of compliance in order to maintain the trust of society and contribute to the healthy development of corporate activities.
  2. Officers and employees shall interact with every person in an earnest, fair, and impartial manner under all circumstances.
  3. Officers and employees shall act with good social conscious and in accordance with the high level of morals and manners expected as a member of society.
  4. Should legal violations or other acts of misconduct be detected, officers and employees shall exercise the courage necessary to speak up and cooperate with any investigations.
  5. Officers and employees shall adhere to the Action Guidelines for Compliance in observing the above guidelines.

Established on October 13, 2021

Yasushi FUjita President and CEO

President and CEO