Group Anti-Bribery and Anti-Corruption Policy
1. Basic Policy
The Change Group prioritizes earning and maintaining the trust of society. We do not tolerate bribery or corruption in any form. We comply with applicable anti-bribery and anti-corruption laws and regulations in all countries where we operate, and conduct our business activities fairly and honestly with high ethical standards.
2. Guidelines for Conduct
(1) Prohibition of Bribery and Corruption
The Change Group does not offer, promise, or provide money, gifts, entertainment, or any other benefit or advantage to public officials, domestic or foreign, for the purpose of obtaining improper advantage. We also strictly prohibit facilitation payments--informal payments made to expedite routine governmental procedures--regardless of the amount.
(2) Promotion of Fair and Honest Business Practices
The Change Group does not solicit, provide, accept, offer, or promise money, gifts, entertainment, or any other benefit or advantage in connection with transactions with business partners other than public officials, in which the appropriateness or transparency of such transactions may be called into question.
(3) Collaboration with Business Partners
The Change Group requests that its business partners, including agents and suppliers, understand the intent of this policy and take measures to prevent bribery and corruption.
3. Establishment and Operation of the Framework
(1) Education and Whistleblowing System
The Change Group provides ongoing training on this policy to all officers and employees. We also maintain a consultation and reporting channel for raising concerns about actual or suspected violations of this policy, thereby promoting the early detection and correction of violations.
(2) Ensuring Transparency and Record-Keeping
The Change Group accurately records all transactions, eliminates unrecorded transactions, and ensures rigorous transparent management.
(3) Monitoring and Continuous Improvement
The Change Group regularly monitors how its anti-bribery and anti-corruption measures are being implemented to verify compliance with this policy. Based on the results of monitoring and changes in external conditions, including social trends and legislative developments, we continuously review and improve our anti-bribery and anti-corruption framework, striving to strengthen its effectiveness.
(4) Response to Violations
If any officer or employee is found to have violated this policy, the Change Group will take strict disciplinary action against that individual in accordance with applicable laws and internal regulations.
* "Change Group" refers to CHANGE Holdings, Inc. and its consolidated subsidiaries (excluding investment limited partnerships, special purpose companies, general incorporated associations, and listed subsidiaries and their subsidiaries).
Date of Enforcement: July 1, 2026
CHANGE Holdings, Inc.