Anti-Corruption Policy

This Policy establishes the fundamental principles for maintaining high ethical standards and complying with applicable laws, regulations, and social norms in all business activities, in accordance with the 2nd RETAILING Group Code of Conduct. The Group is committed to preventing all forms of corruption in order to contribute to society through the sound development of its reuse and retail businesses.

This Policy shall take effect upon approval by the Board of Directors and shall be administered by the Group’s Global Legal Department.

This Policy applies to all directors, officers, and employees of the Group.

The Group also requests the understanding and cooperation of suppliers, contractors, and other business partners with respect to this Policy.

The Group promotes honest and fair business practices and strives to maintain ongoing ethical controls to prevent involvement in corrupt practices such as bribery, conflicts of interest, and money laundering. Managers are responsible not only for conducting their own duties appropriately but also for preventing and promptly detecting corrupt conduct by employees under their supervision.

Whether in Japan or overseas, the Group shall not directly or indirectly offer, request, accept, or promise money, entertainment, gifts, or any other benefit for the purpose of obtaining business advantages or receiving improper preferential treatment.

The Group shall not provide improper benefits to public officials or persons in equivalent positions, whether in Japan or overseas.

The provision of cash, gift certificates, excessive entertainment, kickbacks, or other improper benefits is strictly prohibited. When obtaining permits, licenses, or approvals, or carrying out administrative procedures, the Group shall act appropriately and transparently in accordance with applicable laws and regulations.

The giving and receiving of gifts or entertainment with business partners shall be limited to what is considered appropriate under applicable laws and generally accepted social standards, and the exchange of cash or cash equivalents is prohibited. Approvals and records shall be obtained and maintained in accordance with internal rules as necessary. The Group also prohibits making improper demands for gifts or entertainment by taking advantage of a superior bargaining position.

The Group does not permit facilitation payments, including small payments made to expedite administrative procedures or similar actions.

Donations, sponsorships, and political contributions shall be made only after confirming their purpose and social appropriateness in accordance with internal rules.

Recognizing the high cash-convertibility of the products it handles, the Group understands the importance of preventing financial crimes and strives to ensure appropriate compliance with applicable laws and regulations to avoid any involvement in money laundering or other financial crimes.

The Group seeks to establish fair and transparent business relationships with suppliers, contractors, and other business partners.

To prevent corrupt practices, the Group strives to maintain accurate and appropriate accounting records and books for all transactions.

The Group strictly prohibits improper accounting practices, including creating or maintaining off-the-books assets, submitting fictitious expense claims, making false entries, or keeping double sets of books, and is committed to transparent and fair business operations.

Directors, officers, and employees who become aware of conduct that violates or may violate this Policy, or who believe that they themselves have violated or may have violated this Policy, shall promptly report or consult with their supervisor or the internal whistleblowing hotline.

The Group prohibits retaliation or any other disadvantageous treatment against individuals who make reports in good faith and is committed to protecting whistleblowers.

To ensure understanding of this Policy and prevent misconduct, the Group strives to provide ongoing education and training for its employees.

The Group regularly reviews compliance with this Policy and conducts audits as necessary.

Management shall promote the establishment and continuous improvement of the Group's anti-corruption framework.

The head of each department shall ensure that employees are fully informed of this Policy.

Directors, officers, and employees who violate this Policy shall be subject to strict disciplinary action, including disciplinary measures, in accordance with the Work Rules and other applicable internal regulations, depending on the seriousness of the violation.