Corporate Information

Japan U-Pica Company Ltd. (“the Company” below) defines Compliance as “complying with laws, regulations, internal rules, and social norms with an awareness of corporate social responsibilities to conduct fair, transparent, and independent business activities.”

The Company has established Compliance Consultation Desks to promptly identify and take appropriate preventive/corrective action in the event of compliance issues that the Company cannot or may not be able to resolve through ordinary channels of its organizational structure.

• 1. Persons eligible to use the Compliance Consultation Desks
  　 Company officers and employees and their families, officers and employees of client/affiliated companies, and any other persons involved in the Company’s business activities

• 2. Confidentiality
  　 Members of the Compliance Committee, staff in charge of the Compliance Consultation Desks, and all others involved in investigations shall duly consider the protection of privacy of those who submit consultations or reports and of any persons who cooperate with the investigations (“Whistleblowers” below) and shall disclose names, the fact of reporting, and other details only to the minimum required parties concerned for the investigations or appropriate response.

• 3. Prohibition of Disadvantageous Treatment
  　 The Company shall protect Whistleblowers against disadvantageous treatment, including reassignment, unjust discrimination, or suspension of business transactions. This protection shall be continuously implemented and monitored by the Compliance Committee. This provision shall not apply in cases in which Whistleblowers deliberately make false allegations in reporting or consultations or in cases in which such reporting or consultations are intended for illegal purposes such as entrapment or extortion.

• 4. How to Consult or Report
  　 Please contact any of the Compliance Consultation Desks in writing, by e-mail, or other means that can be recorded to submit consultations or reports, as records need to be retained. You may remain anonymous if you wish.

• 5. Compliance Consultation Desks
  　 The Compliance Consultation Desks can be contacted as listed below: