Media Do
SUSTAINABILITY

SUSTAINABILITY FOR THE MEDIA DO GROUPBASIC COMPLIANCE POLICY AND CODE OF CONDUCT

Basic Compliance Policy

The MEDIA DO Group*1 strives to fulfill its social responsibilities while achieving sustainable growth. All executives, employees, and other personnel*2 act with compliance in mind, aiming to earn the trust of all stakeholders and society.
The establishment, revision, or abolition of this policy shall be made by a resolution of the Board of Directors.

  1. Hereinafter referred to as “the Group”
  2. Including all persons involved in the Group’s operations, such as regular employees, fixed-term contract employees, temporary employees, and outsourced workers. Hereinafter referred to as “executives, employees, and other personnel”

1.Basic Concept

The Group defines compliance as earning the trust of its stakeholders and society, and is committed to the following matters in all aspects of its business activities.

  1. Compliance with laws and regulations, internal rules and manuals, and social norms related to business activities
  2. Appropriate business conduct with appreciation and respect
  3. Prompt implementation of corrective and recurrence prevention measures when compliance violations are identified
  4. Prohibition on taking adverse action against whistleblowers or those who report compliance violations

2.Compliance Framework

The Group takes the following actions to establish a compliance framework.

  1. Appointment of a compliance officer and grant of necessary authority
  2. Centralized management of compliance-related information and development of appropriate reporting framework to management
  3. Development of reporting and consultation framework for compliance

3.Compliance Promotion Activities

The Group establishes the “Compliance Code of Conduct” and takes the following actions to promote compliance.

  1. Establishment of internal rules on compliance and their dissemination to executives, employees, and other personnel
  2. Implementation of periodic training on compliance
  3. Periodic inspections of compliance status by compliance officers

Established: October 13, 2021
Revised: March 1, 2025
President and CEO

Yasushi Fujita

Compliance Code of Conduct

The Group establishes the following guidelines for the conduct of its executives, employees, and other personnel to realize the contents of the “Basic Compliance Policy”.

1.Compliance with Laws, Regulations and Internal Rules

  • We comply with laws, regulations and internal rules, and conduct our business appropriately with gratitude and respect based on social norms and high corporate ethics.

2.Respect for Basic Human Rights

  • We respect basic human rights in all aspects of our business activities and do not engage in discrimination or harassment based on race, nationality, gender, age, occupation, region, creed, or disability.

3.Maintain and Promote a Safe and Secure Work Environment

  • We maintain and promote a safe, secure, and comfortable work environment so that executives, employees, and other personnel can perform their duties to the best of their abilities.

4.Fair and Free Competition

  • We establish and maintain sincere relationships with suppliers, subcontractors, competitors, and other parties, and promote fair and free competition.

5.Protection of Intellectual Property

  • We protect the intellectual property owned by the Group.
  • Executives, employees, and other personnel shall not infringe on the intellectual property of third parties in any way.

6.Environmental Consideration

  • We promote environmental conservation activities by regularly scrutinizing and improving the impact of the Group’s corporate activities on the environment to contribute to the creation of a sustainable society.

7.Proper Tax Payment and Tax Compliance

  • We properly pay taxes in accordance with laws and regulations, as well as optimize tax expenses.

8.Appropriate Information Disclosure

  • We report and disclose information in a timely and appropriate manner so that all stakeholders, including shareholders and investors, can make decisions in a fair and equitable manner.

9.Improvement of Information Security Environment

  • We maintain a secure information system environment by creating an adequate information security environment to prevent unauthorized access, leakage, and falsification of information assets such as personal information and confidential information.

10.Protection and Management of Company Assets

  • We prohibit the personal use of the Group’s assets by executives, employees, and other personnel.
  • The Group establishes internal rules for the acquisition, use, management, and disposal of assets, and appropriately manages these rules.

11.Recording and Storage of Various Information

  • We handle information obtained through our business in an appropriate manner in accordance with relevant laws, regulations, and internal rules.
  • We keep accurate records of our business activities, including accounting and financial records, and do not make fraudulent or misleading records.
  • We maintain records in a manner that allows for retrieval and inspection when necessary, and for timely and accurate disclosure.

12.Appropriate Relationship with Politics

  • We conduct fair corporate activities while maintaining an appropriate relationship with politics. We clarify the purpose and social significance of political donations and contributions to various political organizations, comply with relevant laws and regulations such as the Political Funding Regulation Law, and follow legitimate and transparent methods.

13.Prevention of Corrupt Practices

  • We do not engage in bribery, corruption, extortion, embezzlement or any other corrupt practices.

14.Prohibition of Conflicts of Interest

  • We give priority to securing the interests of the Group in situations where there is a conflict between the interests of our executives, employees, and other personnel and those of the Group, in accordance with relevant laws, regulations, and internal rules.

15.Prohibition of Insider Trading

  • We strictly prohibit insider trading by executives, employees, and other personnel.
  • We strictly control undisclosed material facts to prevent insider trading.

16.Elimination of Relationship with Antisocial Forces

  • We resolutely avoid any relationship with antisocial forces, and strive to prevent the use of our products and services for the transfer of criminal proceeds to ensure the safety of society and sound corporate management.