Direct Marketing MiX Group (Group companies are collectively or individually referred to as the “Company”) recognizes that the impact on human rights, safety, privacy, and other matters associated with the use of AI is an important issue in the conduct of business. We support the OECD AI Principles and other international guidelines, and we are promoting risk mitigation and ethical use in order to contribute to the realization of human-centered AI that can be trusted.

We are establishing the Responsible AI Policy set forth below as a guideline for fulfilling our responsibility to contribute to the realization of a sustainable society. The establishment of this policy was approved by a resolution of the Board of Directors.
This policy applies to all use, introduction, and development of AI, including generative AI, business support AI, cloud-based AI services, and other AI provided by third parties.

We will be mindful of potential bias present in AI training data and algorithms, conduct appropriate evaluation and verification, and strive for continuous improvement to prevent unjust discrimination or disadvantage on the basis of race, gender, age, beliefs, disability, or other such factors.

We will work to maintain the transparency of AI systems, clearly disclose the use of AI when necessary, and strive to provide reasonable explanations of the basis and reasoning of AI-generated results and decisions.
We will also value dialogue with users and other stakeholders and work to develop an environment where AI can be used with peace of mind.

When using and developing AI, we will comply with the Act on the Protection of Personal Information and other applicable laws and regulations and properly handle personal information and confidential information.
To protect AI systems against cyberattacks, unauthorized access, information leaks, and other threats, we will build appropriate security management systems and strive to continuously strengthen them.

Based on a recognition that AI is no more than a tool for supporting and complementing human activities, we will strive to conduct operations with due regard for the roles that AI should play and the limitations of AI. For particularly important decisions, we will maintain systems in which humans actively participate and can appropriately intervene. The Company bears ultimate responsibility for the results of AI use and will respond in good faith and appropriately.

When using AI data centers and AI models provided by the Company and third parties, we will give due consideration to the optimization of energy efficiency and the use of renewable energy and will strive to select models and infrastructure with a low environmental impact (ecological footprint).
We will also promote sustainable AI use by reducing unnecessary computational loads and energy consumption.

The Company will not develop or use AI in any manner that poses a risk of impairing people’s freedom or dignity as set forth below.
• Conduct that improperly manipulates or induces people in a manner that undermines their free decision-making
• Conduct that exploits vulnerabilities related to age, disability, or economic circumstances
• Conduct that unjustly evaluates or ranks an individual’s social reputation (social scoring)
• Identification, surveillance, or tracking of biometric information not pursuant to laws and regulations
• Other use of AI that violates laws and regulations, social norms, or corporate ethics

The Company will comply with relevant laws, regulations, and social requirements and will strive to use AI responsibly.

Established July 24, 2026

1. Fundamental Approach
The Company is aware that while AI and data utilization contribute to the advancement of our business and solutions to social problems, they are also important technologies that entail new risks relating to human rights, privacy, fairness, the environment, and other matters.
With our mission of “Create a future where people can shine” at the core and premised on an appropriate allocation of roles between AI and people, we will promote the responsible use of AI from the perspectives of transparency, fairness, safety, and environmental consideration.

2. Governance System
The Company is examining the management of AI-related risks and opportunities within the framework of our existing corporate governance and risk management systems.
• Data management and security overseen by the Information Management Committee (under the authority of the CISO)
• Control processes audited by the Internal Audit Office
Regarding the introduction and operation of AI, we are working to build a governance system that enables us to assess the impact and likelihood of occurrence of risks based on the existing risk management processes and implement necessary control measures.

3. Consideration for Fairness, Human Rights, and Privacy
The Company recognizes that the impact on human rights associated with the use of AI is a major risk and manages that risk within the framework of our existing human rights due diligence and compliance systems.
• Due consideration to prevent the occurrence of discriminatory or unfair outcomes in AI decision-making and interactions with customers
• Mitigation of bias based on gender, age, attribute, or other characteristics
• Comprehensive protection of personal information and privacy
• Operations in accordance with the Company’s Human Rights Policy and the Code of Conduct

4. Ensuring Transparency
For its services that use AI, the Company strives to ensure transparency so that users can appropriately understand them.
• Disclosure of AI use in responses and content as necessary
• Operations with an awareness of explainability regarding the results of decisions by AI
• Consideration so that users can recognize the involvement of AI and people

5. Model Management and Quality Control
The Company continuously performs monitoring and makes improvements to maintain the quality and reliability of AI.
• Periodic confirmation of the accuracy and behavior of AI models
• Consideration of systemization and creation of remedial action processes for dealing with unexpected outcomes
• Coordination with quality control and operational processes
• Examination of the development and operation of processes to detect and correct AI model deterioration (drift)

6. Grievance and Redress Processes
The Company uses its existing compliance and quality control frameworks to appropriately respond to concerns and issues raised by users and employees regarding business operations and services using AI.
Inquiries and concerns regarding responses using AI are handled appropriately as necessary by using the existing customer response processes and internal whistleblowing system.
• Responses to inquiries relating to business operations using AI through the existing customer response processes
• Confirmation and re-determination by people as necessary to ensure fairness and transparency
• Ability of employees to raise concerns regarding work including AI through the existing internal whistleblowing system and Consultation desk
• Appropriate consideration of and responses to related matters within the existing risk management framework as necessary

Going forward, the Company will continue its efforts to create appropriate redress and response processes in line with the expanded use of AI.

7. Consideration for Environmental Impact
The Company is aware of the impact on the environment from increased energy consumption in conjunction with the use of AI and is implementing the following measures to reduce the environmental impacts.
• Reducing energy consumption through optimization of AI processing
• Expanding use of renewable energy
• Continuous monitoring based on the environmental management system

The Company will also contribute to curtailing indirect environmental impacts such as by reducing paper usage and transportation through improved operational efficiency by using AI.

8. Employee Education and Training
The Company conducts employee training to ensure appropriate AI use and risk management.
• Improved literacy concerning AI use
• Information security and data protection training
• Training on human rights and ethics
• Integrated implementation with compliance training

9. Future Initiatives
The Company will implement the following initiatives in the future to respond appropriately to the emergence of new risks and opportunities from advances in AI technology and to promote sustainable AI use including reduced environmental impacts.
• Further enhancement of AI governance system
• Enhancement of model management and evaluation methods
• Visualization of the impacts of AI on society and the environment
• Consideration of compliance with external standards and certification systems (such as ISO)

10. KPIs and Monitoring
To ensure appropriate AI operations and the effectiveness of risk management, the Company will examine the use of existing KPIs and monitoring indicators.

The main indicators are as follows.
• Information security-related indicators (number of major leaks of personal data, training implementation rate, etc.)
• Compliance-related indicators (number of violations, number of reports made, etc.)
• Customer response quality-related indicators (number of complaints submitted, response quality evaluations, etc.)
• Environment-related indicators (GHG emissions, energy usage, etc.)

These indicators also apply to operations and services that use AI, and the Company is considering their use for early risk detection and continuous improvement.

Going forward, we will enhance indicators and their quantification in order to more appropriately understand risks and impacts unique to the use of AI.