DCM Holdings
Compliance Policy

① Observe Laws, Ordinances and Ethics, Respect Cultures and Customs
Observance of laws, ordinances and ethics both domestically and abroad is a given, and we also observe international declarations, principles and regulations, respect the cultures and customs of all countries and local communities and work to do business sensibly.

② Appropriate Disclosure of Information
We do not engage in any sort of conduct that would cause a loss of societal trust, such as disclosing information or data that is factually incorrect or intentionally concealing details that should be disclosed.

③ Suitable Public Relations
We do not use any phrasing that might be libelous or defamatory towards others, nor terminology that could be related to societal discrimination in any of the documents or information we release for the purposes of PR.

④ Donation and Political Contribution Regulations
When making political contributions or donations to organizations, we will do so in an appropriate manner and in observance of related laws and ordinances such as the Public Officers Election Act or the Political Funds Control Act. Any and all contributions or donations will first be approved following our internal rules. Refraining from bribes, under-the-table payoffs and illegal political contributions is a given, but we will also strictly refrain from any conduct that could give the impression we are in a close relationship with the government or an administration, and will work to build healthy, transparent relationships.

⑤ Refusal of Relationships with Antisocial Forces
To ensure that we are not involved with illegal or antisocial conduct, we always work to act sensibly with basic knowledge of the law, with societal common sense and with a sense of justice. We deal resolutely with the antisocial forces that threaten the order and safety of civil society, and have no relationship with them whatsoever. Additionally, if we receive any undue demands from antisocial forces, we will response resolutely and will not attempt to resolve the matter through money. We will not make use of antisocial forces, either for the sake of the company or for personal gain. We will not conduct any dealings with antisocial forces, nor with businesses that have relationships with antisocial forces.

⑥ Appropriate Use of Information Systems
Use company information systems only for business purposes and not for personal purposes.
We will strictly manage IDs and passwords related to the company's information system to prevent damage such as leakage, theft, destruction and virus infection of confidential information.
We will not steal other people's IDs or passwords or illegally access the system. Regarding the use of the Internet, be aware of the risks of information leakage and diffusion due to e-mail, web browsing, posting on SNS, etc., and the use of generative AI. In accordance with the usage guidelines and the guidelines for business use of generative AI, we will always strive to use it appropriately and will not engage in any act that would undermine social credibility.

⑦ Prohibition of Leakage of Corporate Information
While employed with the company and after leaving the company, we will not leak confidential business information like company secrets learned in the course of our duties, nor information related to products and services.

⑧ Protection of Intellectual Property Rights
Intellectual property rights (inventions, utility models, designs, written works, trademarks, know-how, technical information, etc.) belonging to the company obtained through research, development and other business activities are important company assets, and we work to use these appropriately and to maintain those rights.
Results belonging to the company are promptly applied for and registered, and we work to maintain those intellectual property rights.
We do not engage in any sort of conduct that would infringe on the intellectual property rights of other companies or individuals such as copying the computer software of other companies or individuals without permission. Intellectual property rights of clients are used after the closing of an appropriate contract, and are not used illegally.

⑨ Observance of Laws and Ordinances Related to Import and Export
We act in accordance with related laws and ordinances and handle customs procedures appropriately in the import and export of products.
We in no way engage in the import or export of those items for which import or export is forbidden.

① Product Safety
We give consideration to safety in all aspects of the sale of products, from development and production to sale, maintenance and repair, and we have a sufficient understanding of laws related to safety and safety standards and we observe these while aiming to advance our safety even further. We promptly verify information indicating safety is being impeded when it is obtained, and if it is clear that an issue is present, we contact the relevant departments and take appropriate measures.

② Observance of Anti-Monopoly Act
Regardless of the situation, we will not engage in any activities that violate the Anti-Monopoly Act such as forming cartels, collusion, maintaining resale prices or abusing a dominant bargaining position, and we will engage in competition with other corporations fairly and freely. In particular, we will not engage in unfair business practices, such as selling products at an unreasonably low price or limiting the sale prices of our sales contacts.

③ Appropriate Dealings with Clients
When dealing with clients, we engage with common sense and integrity, and treat them fairly and equitably. When selecting clients from a number of different businesses, we fairly compare and evaluate conditions such as quality, price, delivery, technical development ability, stability of supply and credibility, and choose the optimal client. We will not engage in conduct that unduly favors any specific client.
When consigning manufacture or repair to clients, we pay careful attention to ensure that there are no delays to payment and engage in contracting and dealings with sufficient understanding of the Subcontract Act.
Additionally, we ask that clients agree with and work in the spirit of our compliance statement and code of conduct.

④ Prevention of Unfair Competition
We will not acquire nor use the business secrets of other companies through illegal means such as theft. We will not acquire nor use the business secrets of other companies if we know that they were acquired illegally or if we know that there is risk thereof.

⑤ Prohibition of Inappropriate Entertaining and Exchange of Gifts, Bribery
When entertaining or exchanging gifts with clients, it will be done within the scope of social courtesy. If we have no choice but to accept entertaining or gifts from customers or clients, we will do so within the scope of social courtesy.
We will not engage in any form of bribery.

① Disclosure of Management Information
In addition to releasing management information such as the company’s financial details and the state of business activities to stockholders and investors in a timely and appropriate manner, we will also clearly communicate our management philosophies and policies.

② Prohibition of Insider Trading
We will not use insider information acquired through business related to clients we have business relationships with, competing companies and customers to buy or sell those companies’ stocks or bonds before that information has been disclosed publicly to general investors.
We will not use insider information acquired in the course of our duties to buy our sell our own stocks or bonds.
Additionally, our executives observe the regulations for the trading of their own company stocks by executives laid out in the Financial Instruments and Exchange Act.
Even if an intermediary is used, or no personal gain is made, these acts are unacceptable and we will not engage in them.
We will not talk to others, even our families, about insider information acquired in the course of our duties.

①Respect for Human Rights, Prohibition of Discrimination
We always work to maintain a healthy work environment, respecting the human rights of all individuals and not engaging in any conduct that could be tied to discrimination.
We will not conduct any discrimination on the basis of race, nation, sexuality, language, age, religion, political or other opinions, thoughts and beliefs, nationality, social background, assets, birthplace or any other factors (sexual orientation, gender identity, health status, presence of disability).
We will not compel employees to work through violence, derogatory remarks, abuse, slander or coercion and will not infringe upon human rights through things such as bullying.

②Sexual Harassment
We will not engage in sexual harassment, or anything that could be considered or mistaken as sexual harassment, or any sexual speech or behavior that could cause the other party to feel uncomfortable.

③Power Harassment
We will not overstep reasonable work boundaries and cause mental or physical anguish, nor worsen the workplace environment for those we work with on the basis of position in the company or superiority in relationships.

④Harassment Related to Pregnancy, Childbirth, Child Rearing or Nursing
We will not use any speech or behavior to imply the dismissal of or other disadvantageous treatment to those who would use systems and measures related to pregnancy, childbirth, child rearing and nursing, nor any speech or behavior that would inhibit the use of said systems and measures, nor will we harass anyone who has used said systems and measures.

⑤Protection of Privacy
Personal information of employees or those outside the company acquired in the course of business will only be used for business purposes and will be carefully managed. Additionally, this information will be carefully managed to ensure that it does not leak.

⑥Workplace Safety and Health
We work to create a workplace with precedence on securing safety and health, and we understand and observe laws and ordinances related to safety and health in business. On the off chance that there was a workplace accident, we will minimize the damage from the accident and will ensure that we move forward with designated procedures to prevent a reoccurrence, such as real-time reporting.

⑦Traffic Safety
We observe traffic rules and pay suitable attention to driving, both in commuting to the company and on days off, and, in particular, we will never engage in traffic violations such as driving under the influence of alcohol.

⑧Observance of Labor Laws
We observe the labor laws and work to maintain a healthy workplace environment that is easy to work in. We observe the Labor Standards Act and do not compel employees to engage in work like excessive labor or overtime. We engage in deliberations with labor unions earnestly, and construct healthy relationships between labor and management. Managers pay careful attention to the mental and physical health of their subordinates.

⑨Observance of Work Regulations
We keep work discipline and observe items laid out in work regulations. We respect the employee’s rights that are laid out in these work regulations.

⑩Appropriate Accounting Management and Tax Processing
Relevant laws and ordinances and internal rules are followed in the recording in the account ledger and filling in payment slips. We will not falsify nor conceal the truth, enter deceitful or fictional information, nor will we have assets that are off the books.

⑪Appropriate Use of Company Assets
We use company assets efficiently, are aware that they need to be available at a moment’s notice, and handle them appropriately to prevent damage or theft, whether material or immaterial. We will not use company assets nor expenses for personal aims.

①Appropriate Procedures for Approval, Authorization, and Notification
We ensure implementation of procedures for approval and authorization, as well as for notification.
We do not neglect necessary notifications that should be sent out, nor do we engage in any sort of conduct that would cause a loss of societal trust, such as data falsification.

②Prohibition of Inappropriate Entertaining and Exchange of Gifts, Bribery with Civil Servants
We do not entertain nor exchange gifts with civil servants or their equivalents in any way that would violate the National Public Service Ethics Act nor the rules laid out at government agencies.
Additionally, we do not give benefits such as money, nor do we make promises or offers thereof to executives and staff of foreign governments as a means to receive illegal profits in business or in return for advantages in business.
We will not engage in any form of bribery.

Contributions to Society
As good corporate citizens, we are working to protect the global environment, actively participating in activities that make contributions to society and making contributions to the development of society.