Operating fairly and in compliance with the law and the rules of society, and as a responsible member of society, the Hakuhodo DY group acknowledges the following statements about our work and accepts the corresponding obligations.

• a) We handle critical information relating to our business partners
• b) Our work involves the management of rights
• c) Communication is our field of business
• d) People are our greatest asset
• e) We do not engage in any anti-social activity
• f) We act with responsibility toward our stakeholders
• g) We are a transparent and law-abiding group
• h) Our group strives for global quality

Aiming to maintain and increase the trust that society vests in the activities of the Hakuhodo DY group, we clearly affirm these matters with which every employee and corporate officer is expected to comply.

• a) Management of confidential information
• b) Prohibition of insider trading
• c) Matters of compliance regarding conflict of interest
• d) Non-disclosure obligations, both during and after the term of employment
• e) Matters of compliance regarding external activities
• f) Matters of compliance regarding business entertainment and gift-giving
• g) Restrictions on meetings with government and other public officials, and members of like organizations
• h) Handling of any instance of breach of these Matters for Compliance
• i) Injunctions of the internal bodies handling whistle blowing and consultation