Compliance and Risk Management Policy

1. Basic Policy

To respond to the trust and expectations of society and to form a solid management foundation supporting sustainable growth, the Change Group strongly pledges to conduct all business activities based on compliance with laws and regulations, fair trade, and the exclusion of anti-social forces.

Furthermore, we strive to ensure business sustainability by foreseeing risks that threaten corporate activities in advance, and planning and executing appropriate countermeasures.
To realize these goals, we will build and strengthen the compliance and risk management system across the entire the Change Group, and all officers and employees will strive to understand this basic policy and utilize it as a guideline for their conduct in management execution and daily operations.

2. System Development and Operation

To reliably realize this basic policy, the Change Group will establish and operate a compliance and risk management system as follows.

(1) Exhibition of Leadership

The management team of each Change Group company will exhibit leadership for compliance and risk management, convey its importance to officers and employees, and implement various measures related thereto. Additionally, the department heads of each Change Group company will supervise the compliance and risk management of employees affiliated with their departments and strive to prevent the occurrence of compliance violations and the materialization of risks in daily operations.

(2) Establishment of Group Compliance & Risk Management Committee

To promote and supervise compliance and risk management across the entire Change Group, we will establish the "Group Compliance & Risk Management Committee" chaired by the Representative Director of CHANGE Holdings. This Committee will meet regularly to comprehend the status of compliance and risk management across the Change Group, implement various measures, and take necessary actions as required.

(3) Employee Education and Awareness Activities

We will conduct regular education and awareness activities concerning compliance and risk management so that all officers and employees of the Change Group can understand this basic policy and reflect it in their management execution and daily operations.

(4) Exclusion of Involvement of Anti-Social Forces

We will conduct investigations to confirm that there is no involvement with anti-social forces among the Change Group's business partners and related parties. In contracts with our business partners, we will explicitly state clauses regarding the exclusion of anti-social forces, and if a violation occurs, we will terminate contracts and take other necessary measures.

(5) Establishment of Internal Whistleblowing Hotline

The Change Group will establish a common internal whistleblowing hotline to create an environment where compliance violations and other offenses can be detected early and corrected.

3. Evaluation and Improvement

The Change Group regularly evaluates the effectiveness of the compliance and risk management system and its operational status, and plans and executes countermeasures and improvement plans as necessary.

Additionally, with the Group Compliance & Risk Management Committee taking the initiative, we identify the status of compliance violations, the operational status of the internal whistleblowing hotline, and the effects of education and awareness activities for employees. We also regularly conduct risk evaluations of each Change Group company and, based on these results, perform reviews of measures and implement improvements.

4. Related Policies

• Change Group Code of Conduct
• Policy for Anti-Social Forces
• Information Security Policy

Date of Enforcement: October 1, 2024
CHANGE Holdings, Inc.