The company has established the “Tsukishima Holdings Group Corporate Code of Conduct: Our Five Commitments” as a compliance code for all executives and employees, and we have established the “Tsukishima Holdings Group Corporate Action Guidelines” to describe principles of specific actions with which each and every member of the organization should comply. Practical details of the Corporate Action Guidelines are outlined via individual internal rules (including the Basic Rules on Protection of Personal Information, Rules on Management of Trade Secrets, the Antimonopoly Act Compliance Program, and Insider Trading Prevention Rules). We have set up a structure built upon three lines of defense to establish mutual checks and balances to enhance compliance. These lines of defense are business divisions (first), administrative sections (second), and internal auditing sections (third). We provide compliance training for Group employees through in-person training, online training, e-learning, and other programs. Compliance training in FY2023 addressed 10 themes, including information security and the Antimonopoly Act. The percentage of eligible personnel undergoing the training in FY2023 was close to 100%. We have designated October of each year as Tsukishima Holdings Group Corporate Ethics Month, during which intensive awareness promotion activities are conducted to ensure that an understanding of compliance has been instilled throughout the organization.

As the holding company, Tsukishima Holdings is responsible for enhancing Group management and formulating and promoting management strategies based on an overview of the entire Group, while operating companies are accelerating decision-making, thus improving the efficiency of Group management and achieving further advances in governance. To achieve these goals, the Group compliance structure calls for periodic reports from Group companies and prior approval for important matters based on the Tsukishima Holdings Group Company Management Rules. To ensure the efficacy of in-house rules, we have formed the Tsukishima Holdings Group Compliance Committee, chaired by the President. The Director in charge of the Compliance Committee serves as the deputy chair, while general managers of individual Tsukishima Holdings sections are appointed as members, Directors of individual Group companies are appointed as persons responsible for compliance. Through employee guidance on the Corporate Action Guidelines and other activities, the committee develops and maintains a structure for ensuring the propriety of the business operations of Tsukishima Holdings and Group companies. Internal auditing sections implement internal audits of the state of operations at Tsukishima Holdings and Group companies based on internal audit plans, and the results are reported to the Company Board of Directors and Board of Corporate Auditors. In addition, Directors and Corporate Auditors are dispatched to Group companies for purposes of oversight and checks and balances regarding the business execution of these companies.

The Group has established the Tsukishima Holdings Group Corporate Ethics Helpline to prevent or quickly detect any actions that violate laws, regulations, or the articles of incorporation. In addition to the internal helpline and a hotline for reporting matters directly to the Company’s full-time corporate auditors, we have established external contact points for whistleblowing reports at attorneys and a contracted specialized agency independent of the Company. To promote awareness of the helpline, we are distributing helpline cards to employees and posting a helpline usage guide and an overview of its system on the intranet.