SUSTAINABILITY

Code of Sustainable Conduct,Promotion System

DmMiX Group Code of Conduct

The Direct Marketing MiX Group Code of Conduct stipulates the basic policies of the Direct Marketing MiX (DmMiX) Group (both Group companies as a whole and specific Group companies) based on our corporate philosophy and has been compiled as a guideline so that every individual in the Group is deeply aware of the Group’s social responsibilities, complies with laws, regulations, in-house rules, etc. in the execution of their daily work, and practices conduct befitting social ethics.

Focusing on corporate ethics, this Code of Conduct aims to enhance the Group’s corporate value by promoting conduct based on a sound sense of ethics.

We will obey the laws, regulations, and other rules in countries where we conduct business activities. To promote our social and environmental responsibilities and business ethics, as well as complying with laws and ordinances, we will conduct ourselves in respect of the Ten Principles of the United Nations Global Compact, the core labor standards of the International Labour Organization (ILO), the Guidelines for Multinational Enterprises of the Organization for Economic Co-operation and Development (OECD), the Universal Declaration of Human Rights, and the Guiding Principles on Business and Human Rights.

Coverage

This Code of Conduct applies to all executives and employees of the DmMiX Group. As well as regular employees, this includes temporary and part-time workers.

Establishment, Amendment, and Abolition

Establishment, amendment, and abolition of this Code of Conduct will be decided by the DmMiX Board of Directors.

Contents

1. Fair operating practices
2. Respect for Individuals and Job Satisfaction
3. Relations with Society
4. Initiatives for Environmental Preservation
5. Thorough Information Security

1. Thorough Practice of Fair Corporate Activities

As a truly trusted corporate member of society, the DmMiX Group will obey laws, ordinances, and other rules and act with sincerity.

1.1 Basic stance

The executives and employees of the DmMiX Group will comply with laws, ordinances, and respect for social norms, and in-house rules in the countries and regions where we conduct business activities and conduct themselves with a high level of ethics in both their work and private lives. We are aware that the leakage of customer information and other in-house confidential information is a serious and wrongful act and will conduct ourselves accordingly. In relations with customers, business partners, etc., we will strictly refrain from offering and receiving excessive gratuities.

1.2 Free and fair competition

We will engage in fair and transparent transactions with all business partners in compliance with antimonopoly laws and other related legislation and thoroughly understand and obey the purpose and content of competition-related legislation in each country and region.

(1) Fair, transparent, and free competition and appropriate business

We will endeavor to acquire customer satisfaction and trust by supplying highly creative services that are useful to society and paying attention to the quality of services provided, reliability, and information security. Furthermore, we will not engage in any act that hinders fair, transparent, and free competition, such as unfair business restrictions like bid rigging to decide order prices and unreasonable business practices like the abuse of one’s superior position to unfairly place others at a disadvantage in terms of business conditions and implementation.

1.3 Prevention of corruption

To ensure the soundness of our business activities, we will endeavor to comprehensively prevent acts of corruption, such as bribery, insider trading, and the misappropriation of company assets, etc.

(1) Prevention of bribery

We will not engage in acts that might be suspected of constituting bribery to customers, suppliers, other business partners, and civil servants or the equivalent (including civil servants of countries other than Japan). We will stipulate in-house rules based on important legislation and ordinances, thoroughly disseminate this education, comply with outside business and in-house regulations, and strive, through process management, to prevent bribery.

(2) Prevention of insider trading

To ensure the fairness and soundness of securities markets and to win the trust of shareholders and investors, we will endeavor to prevent insider trading. We are implementing e-learning for all executives and employees of Group companies and continuously organizing education for them so that they do not engage in stock trading using undisclosed information obtained in their work.

(3) Prevention of misappropriation of company assets

We undertake proper management, such as regular volume checks, so that company assets, such as equipment, furnishings, inventory, rental goods, and cash, are not lost, and we do not appropriate company assets for private purposes. Furthermore, we properly manage private information and confidential company information and do not use such information beyond the stipulated objectives and conditions.

(4) Prevention of third-party corruption

If we conduct business through a third party, such as a consultant, consignee, broker, or sales agent, we will make efforts so that they comply with anticorruption rules in the same way as our own executives and employees. We conduct appropriate due diligence and will not engage in business with any third party unless a written contract has been concluded.

2. Respect for Individuals and Job Satisfaction

Recognizing that respect for human rights is an important social responsibility of a company, we respect the diversity, personality, and individuality of all executives and employees and strive to ensure safe and work-friendly workplace environments in which they really can feel job satisfaction.

(1) Respect for human rights and diversity

We will fulfill our responsibility to respect the human rights of all people. This means respecting customers and other stakeholders and every individual working in the Group; not discriminating for reason of gender, age, nationality, race, ethnic group, beliefs, creed, religion, social status, sexual orientation or gender identity, disability, differences in type of job and employment pattern, etc.; and paying the same wage for the same job whether performed by a male or female employee. We will endeavor to respect diversity so that all executives and employees can display their individualities and become an enterprise brimming with the joy of work and growth opportunities.

(2) Realization of work-life management

We will endeavor to build workplace environments in which executives, employees, and cooperating persons can work safely, securely, and comfortably, enjoy good health both physically and mentally, and get lots of job satisfaction. Furthermore, we will arrange an environment that enables all executives and employees to work flexibly and balance their job with parenting, nursing care, medical treatment, and so on, thereby helping everyone to work enthusiastically and fully display their abilities and achieving both corporate development and individual well-being.

(3) Realization of human resource development and career formation

We will evaluate the abilities of all executives and employees objectively in accordance with a fair evaluation system and, while respecting their aptitude and independence, assist their career formation by, for example, assigning the right people to the right positions. Furthermore, in addition to group training and on-the-job training for employees to acquire the specialized skills required in each field of business, we will provide opportunities for employees to be even more active through, for example, correspondence courses for self-study, e-learning, an in-house qualification system to measure the results of these activities, and assistance in the acquisition of qualifications.

(4) Prohibition of harassment

Our executives and employees will respect one another and will not engage in acts that offend the dignity of others, such as sexual harassment and power harassment, disrupt workplace discipline and order, or obstruct the execution of work.

(5) Prohibition of child labor and forced labor

We will not employ children under the minimum working age stipulated by the country or region concerned and will not enforce labor against the will of the worker.

(6) Appropriate working hours

Working hours must not exceed the maximum time stipulated in local laws and local regulations and, including overtime, must not be excessive. Overtime requires consent in a labor agreement, labor union contract, or work rules and will not be enforced otherwise.

We conduct monitoring through our Internal Audit Office and endeavor to reduce excessive working hours. In principle, maximum overtime is 35 hours/month. (In special circumstances only, the maximum is 70 hours/month.)

(7) Appropriate wages

To protect the right to a minimum wage, we comply with local laws and local regulations and related ILO conventions. Furthermore, we pay appropriate wages based on legislation to our workers.

(8) Freedom of association and right of collective bargaining

We comply with labor principles and regulations as defined by the International Labor Organization and other international bodies, as well as the laws and ordinances of each country or region, and respect workers' freedom of association and right to engage in collective bargaining.

3. Relations with Society

We will respect national and local cultures and customs, take account of the interests of stakeholders, and contribute to society with resolve and responsibility by stipulating priority areas and conducting activities continuously.

(1) Respect for diverse cultures and customs

Our executives and employees will respect national and regional histories, cultures, and customs and act accordingly.

(2) Practice of social contribution activities to contribute to local communities

In fulfilling our social responsibilities, recognizing that directly or indirectly addressing the challenges and problems faced by society has become a requirement from stakeholders, we will actively fulfill our responsibilities as a member of society by not only supplying socially useful services but also promoting job creation, contributing to the local economy, etc.

(3) Fostering of a corporate culture that values social contribution activities

Our executives and employees will seek to foster a corporate culture that values social contribution activities by actually conducting volunteer and other social contribution activities.

(4) Basic stance toward the exclusion of antisocial forces and related measures

We will adopt a resolute stance toward antisocial forces that pose a threat to social order and the security of civil society and will not have any relations whatsoever with such organizations or individuals.

If we come into contact with such organizations or individuals, our policy is to adopt an organizational response immediately and, in collaboration with the police, related groups, and others, firmly refuse unreasonable and illegal demands.

Furthermore, in preparation for unforeseen circumstances, we will gather information relating to antisocial forces and keep an eye on trends. In the event of us having ties of some kind with antisocial forces without our knowledge, we will promptly sever such relations in collaboration with the police and other related bodies.

4. Initiatives for Environmental Preservation

Recognizing that climate change caused by an increase in greenhouse gas emissions is a serious issue impacting business activities, we will endeavor to reduce our environmental load and tackle the mitigation of climate change by, among other initiatives, improving the efficiency of our energy use, reducing our use of resources, preserving biodiversity, and promoting waste reduction, and at the same time we will achieve business growth.

(1) Reduction of our environmental load from business

We will contribute to the reduction of greenhouse gas emissions by improving the efficiency of our business activities, promoting a resource cycle, and reducing our load on the environment.

As one aspect of our efforts to reduce greenhouse gas emissions, we will endeavor to save electricity and reduce electricity consumption by encouraging executives and employees to wear lighter clothing in the summer, refraining from the excessive use of air conditioners, adjusting the temperature of air conditioners in workspaces, switching off unnecessary equipment, and adopting measures to raise the environmental awareness of executives and employees.

Furthermore, we will actively utilize renewable energy and thereby contribute to the reduction of CO2 emissions and climate change adaptation.

5. Thorough Information Security

Depending on the degree of importance, we will appropriately and strictly manage information that is created or acquired in business as confidential corporate information.

In addition, again depending on the degree of importance, we will manage information collected and used by ourselves about third parties (customers, business partners, cooperating companies, etc.), and information entrusted to us by third parties, as confidential corporate information.

Furthermore, information security risks, such as the leakage of private or customer information, have an enormous impact on corporate activities. Therefore, believing that raising the awareness and understanding of every executive and employee regarding the management of information assets is most important, we implement training for all of them.

(1) Thorough management rules

If our executives or employees create or acquire information, materials, documents, etc. in their work, they will report the matter to a senior employee and manage the items in accordance with our related rules, etc. Furthermore, after retirement, they will comply with our written stipulations to prevent the leakage of confidential company information.

(2) Authorized disclosure

If our executives or employees receive a work-related question or request to supply materials, regardless of whether it is from inside or outside the company, excluding clear cases in which they have the authority to reply to the question or the authority to respond to the request to supply materials, they will refer to a senior employee for directions on how to handle the matter.

Established on November 12, 2021.

Promotion system

Sustainability Initiative Implementation System

We believe that sustainability initiatives undertaking with the objectives of pursuing the sustainable development of society and continuous enhancement of corporate value are crucial management issues, and we established a Sustainability Committee as an internal organ of the Board of Directors to conduct sustainability management. Sustainability is a companywide initiative, and for this reason, President and CEO, Representative Member of the Board of Directors Yuki Kobayashi serves as chair of the Sustainability Committee.

The Sustainability Committee was established in November 2021 and held its kickoff meeting that month with all members in attendance. Going forward, the Committee plans to meet once a quarter.

The Sustainability Committee will deliberate on strategies and action plans with the understanding that environmental issues including climate change, social issues including human rights and human resources, and corporate governance issues including compliance are all sustainability issues and disseminate those strategies and plans to the entire group. The Committee will also work with the Risk and Compliance Committee to manage and mitigate risk.

The Sustainability Committee will provide advice and reports to the Board of Directors on the subject matter of its investigations and discussions, and the Board of Directors will periodically monitor this process and provide direction as necessary.

In this manner, we will respond to environmental changes and reinforce our management foundations.

For details, please refer to the Corporate Governance Report (p. 3).

Structural Diagram of
the Sustainability Committee
Board of Directors
Advice & Reports
Sustainability Committee
Chairperson: President and CEO,
Representative Member of
the Board of Directors
Members : Responsible member of
the Board of Director
Women’s Empowerment Officer