Compliance

Fair Trade
The Company takes the following steps to ensure it conducts fair and transparent transactions with all of our customers and business partners based on the principle of free competition and in compliance with the Antimonopoly Act, Subcontract Act, and all relevant laws and regulations.

• No private monopolies
• No unreasonable restraints on transactions (such as by cartels or collusive bidding)
• No unfair business practices
• Full compliance with the Subcontract Act

Prohibition of Bribery
The Company does not provide money, gifts, entertainment, or any other form of benefits designed to produce an inappropriate influence for receiving or maintaining business or for securing an inappropriate business advantage from third parties, including public employees and private business partners, directly or indirectly. The Company also does not accept money, gifts, entertainment or other benefits that may affect the Company’s decision.

Protection of Intellectual Property Rights
The Company takes appropriate measures in its business activities to protect intellectual property rights, such as patent rights, design rights, trademark rights, utility model rights, and copyrights of copyrighted works, including computer programs. The Company also implements every possible measure to protect the Company’s intellectual property rights and to fully respect and not intentionally misuse or infringe upon the intellectual property rights of third parties.

Internal Whistleblowing System
To strengthen compliance, NEOJAPAN has adopted an Internal Whistleblowing System based on the Internal Whistleblowing System Rules. The Internal Whistleblowing System has been made even more effective by establishing hotlines with directors responsible for administrative sections and with auditors in addition to a direct hotline with a third-party law office.