Our company has carried out corporate activities aimed at constructing favorable relationships with various stakeholders. In the future, the preservation and expansion of these relationships will be vital to the continued existence and development of our company. Furthermore, these corporate activities are an accumulation of the actions taken by each and every person who works there. As a result, in order to be a company that is appreciated by its various stakeholders, all of its employees must observe laws and regulations, hold high regard for social norms, and act in accordance with corporate ethics. In other words, it is our belief that a thorough level of compliance is something that is absolutely necessary.

In regards to compliance, we have created the following basic policy.

• 1. Our Group, as a member of society, must meet the expectations of a variety of stakeholders and develop its business while striving to be a company that is trusted.
• 2. Our Group must observe the laws and regulations and internal regulations, hold high regard for social norms and common sense, and act in accordance with corporate ethics in order to ensure that compliance is established.
• 3. Our Group will encourage a thorough awareness of the company’s Management Philosophy, Corporate Philosophy, and Code of Conduct, and by ensuring compliance with these will motivate the employees to move in the direction in which Suncall is aiming in order to expand the corporate value of the entire Group as a result.

Compliance System

Compliance Regulations are being established which outline a system for constructing, maintaining, and improving our Group’s compliance system, as well as items which must be observed.
Based on those regulations, a Compliance Committee is being formed which will study and promote policies and measures related to CSR, promote and improve the compliance system, work to ensure thorough awareness of the Corporate Philosophy, Management Philosophy and Code of Conduct, and conduct overall management. The heads of each business unit, as well as presidents of each subsidiary, will be positioned as Compliance Officers, and will report periodically to the Compliance Committee regarding the status of compliance at each place of work. Also, during operating audits, the Internal Auditing Office will carry out hearings and monitoring regarding the observation status of Suncall Group Code of Conduct from a compliance standpoint and report the results thereof, as well as any other findings, to the Compliance Committee.

Code of Conduct

The ’ Suncall Group Code of Conduct’ refers to the "CSR Policy," which shows all of our CSR activities within and outside the company, and the "Code of Conduct," which indicates that employees can act in a manner that considers the practice of compliance as an employee. We distribute it to all employees and center on education for compliance.

Compliance Training

In addition to implementing compliance training when new employees join the company and when employees are promoted to be managers, outside instructors will be invited to perform group training and DVD-based educational materials will be circulated to promote compliance.

Compliance News

Via “Compliance News”, the Compliance Committee Office will disseminate information regarding decisions made by the Compliance Committee, as well as revisions to related regulations.

Compliance Enhancement Week

During the “Compliance Enhancement Week” held once annually by our company, compliance awareness is cultivated by communicating the message from the President regarding compliance to employees, distributing a special edition of Compliance News issued for Compliance Enhancement Week within the company, having employees participate in compliance surveys, and by implementing educational campaigns using posters and tabletop stands.

Hot-Line (reporting system)

At our company, a hot line (reporting system) independent of management has been created to which employees can voice their concerns or report matters by way of email or written letter when they discover behavior that violates the “Suncall Group Code of Conduct” or when they find something to be suspicious and feel unable to resolve the matter themselves or at their place of work. This system protects the company by minimizing the scale of problems through early detection and correction of inappropriate actions. This hot line connects users to the Compliance Committee Office, as well as to outside legal counsel. The company has created the following regulations to protect the privacy of employees when reports are received and matters in question are investigated.

• (1)The company shall under no circumstances treat an employee, etc., unfavorably for making reports or seeking consultation.
• (2)The company shall take appropriate measures to prevent the workplace environment of the employee who made the report, etc., from being negatively affected.
• (3)If an employee, etc., who made a report is treated unfavorably or suffers harassment (retaliatory behavior), etc., the company shall penalize the party responsible in accordance with Employee Regulations.

For early discovery and remedy of any problem, Suncall has established and is operating the Hot Line to receive reports and consultation requests from business partners who have noticed a breach of compliance or an act with a risk of breaching compliance. In case a business partner notices any breach of compliance or other act with a risk thereof by Suncall or our employees, please report to Suncall via the means described below. When Suncall accepted the prescribed notice about the report, Suncall will swiftly investigate and resolve the problem. The information that reported and Sucall accepted the prescribed notice about the report, will be subject to fact checking and investigation, and in principle, the reporting person will be informed of the results. (Please note that reports that are not relevant to a breach of compliance may not be applicable for such follow-up.) When reporting, please refer to and accept the “Precautions for Reporting to the Business Partner Hot Line” below and send a message to the e-mail address for the Business Partner Hot Line.