Company
Code of Conduct

KOEI TECMO Group Code of Conduct

Scope of Application
This Code of Conduct applies to directors, corporate auditors, and employees of the KOEI TECMO Group, as well as part-time employees and other staff who have entered into an employment contract with the KOEI TECMO Group, and to seconded employees and temporary staff accepted under secondment or dispatch agreements (collectively referred to as "Group Employees").

Practicing Our Basic Ideology
Group Employees shall ensure the KOEI TECMO Group's purposes of "Creativity & Contribution" and "Level up your happiness," along with its vision of "To Become the World's No. 1 Digital Entertainment Company," and shall practice the values that shape our culture and the Basic Management Policies that set out the roles and responsibilities of those who lead management.

What is the Code of Conduct?
The KOEI TECMO Group Code of Conduct sets out the standards for action and judgment for each Group Employee in order to put our basic ideology into practice.

• Basic Principles

  • Maintaining High Ethical Standards
    In the spirit of "Creativity & Contribution," Group Employees shall conduct themselves with high ethical standards, carrying out their duties with integrity as responsible members of society.
  • Compliance with Laws and Social Rules
    The KOEI TECMO Group respects and complies with laws, regulations, customs, and other rules recognized as socially fair in every country and region where it conducts business. It is the responsibility of each Group Employee to understand and comply with the social rules and internal regulations applicable to their work.
  • Internal Reporting
    
    Group Employees are encouraged to promptly report to their supervisor or the contact points listed below if they discover, within the company, any act that violates laws and regulations related to business operations, any act highly likely to constitute such a violation, or any violation of internal regulations.
    The KOEI TECMO Group has established multiple internal and external contact points, including a whistleblowing hotline, so that reports can be made at any time. The KOEI TECMO Group will not dismiss a whistleblower or otherwise subject them to any disadvantageous treatment on the grounds that they have consulted about or reported such matters. The KOEI TECMO Group will take appropriate measures to ensure that a whistleblower's work environment does not deteriorate as a result of having consulted about or reported such matters. Furthermore, any person who subjects a whistleblower to disadvantageous treatment or harassment will be disciplined in accordance with the Work Regulations of the relevant KOEI TECMO Group company.

• Respect for Human Rights

  • Respect for and Protection of Human Rights
    The KOEI TECMO Group and Group Employees respect and protect the fundamental human rights internationally declared and guaranteed in each country, and shall not infringe upon the fundamental human rights of anyone involved in the business activities of the KOEI TECMO Group. In addition, we shall not engage in discrimination or harassment based on nationality, race, ideology or beliefs, age, gender, sexual orientation, physical condition, or other such attributes. We pursue efforts to respect personality and individuality so that diverse individual values are recognized and personal dignity is not undermined.
  • Prohibition of Forced Labor and Child Labor
    The KOEI TECMO Group does not, under any circumstances, require anyone to work by force or against their will. Nor does it employ children. We will seek the same standards not only within the KOEI TECMO Group but throughout our supply chain. Here, "child" refers to a person under the age of 15 (or under 14 where permitted by the laws of the relevant region), or, where the minimum working age stipulated by the laws of the relevant region is higher, a person under that age. However, this policy does not apply, to the extent permitted by the laws of the relevant region, to occupations such as actors, singers, musicians, and other work where the nature of the job reasonably requires the labor of children (for example, child actors).

• Enhancing the Workplace Environment

  • Encouraging Creativity and Initiative
    Group Employees shall always act with creativity and initiative. The KOEI TECMO Group strives to cultivate imaginative talent and foster a free and open corporate culture, thereby promoting the challenge of new fields.
  • Providing a Safe and Secure Workplace
    The KOEI TECMO Group strives to create a workplace where employees can work with peace of mind. We shall not engage in discriminatory speech or conduct, violence, harassment, or any other act that disregards an individual's character or undermines the workplace environment. We shall also appropriately manage working hours and create a rewarding workplace so that Group Employees can maintain both physical and mental health and demonstrate high performance.
  • Fair Evaluation and Treatment
    The KOEI TECMO Group evaluates and treats all of its employees with fairness. We shall not discriminate against applicants or employees in employment-related matters such as recruitment, hiring, and promotion on unreasonable grounds such as nationality, race, ideology or beliefs, gender, age, sexual orientation, or physical condition.

• Fair Business Practices

  • Fair Trade
    In every country and region where it conducts business, the KOEI TECMO Group thoroughly understands and complies with the purpose of antitrust laws, laws concerning fair transactions, and other laws and regulations for maintaining fair competition. We shall not enter into agreements with competitors that restrict competition, such as fixing sales prices or limiting supply, nor shall we demand that business partners maintain resale prices. We shall not engage in unfair price negotiations with business partners or abuse a superior bargaining position as defined under antitrust law.
  • Mutual Development with Business Partners
    The KOEI TECMO Group aims to achieve mutual development with its business partners by complying with laws and regulations and conducting transactions on fair terms.
  • Conflicts of Interest
    Group Employees shall always conduct business based on high ethical standards, comply with internal regulations when making business decisions, and act so that personal interests do not affect business judgment. If there is a possibility, or a suspicion, that a personal conflict of interest may arise between oneself and a third party, employees shall promptly report this to their supervisor.
  • Prevention of Bribery and Corruption
    Group Employees shall not provide any money, goods, or entertainment to business partners for the purpose of winning business or receiving any other unfair business advantage. Even where no benefit in return is expected, Group Employees shall not provide or receive money, goods, or entertainment beyond the bounds of normal social courtesy. With respect to public officials, Group Employees shall not provide any money, goods, entertainment, or other benefit, regardless of purpose or circumstance.

• Creating Value through High Quality

  • Pursuit of Customer Satisfaction
    The KOEI TECMO Group strives to maximize customer satisfaction by providing products and services, together with appropriate pricing and information, that exceed customer expectations. We shall respond to customer inquiries and complaints sincerely and promptly. Where we judge that a demand or conduct is socially unreasonable, we will take organizational measures, including legal action where necessary, in order to protect the human rights of our employees.
  • Developing Products and Operating Services with High Ethical Standards
    The KOEI TECMO Group is keenly aware that a company that pursues only its own profit will be denied its place in society, and therefore conducts business with a spirit of compliance and high ethical standards at all times. The KOEI TECMO Group remains constantly mindful of the impact its products and services have on society, and develops and provides them with high ethical standards. In particular, we develop products and services with careful consideration for the sound physical and mental development of young people.
  • Contributing to Communities Worldwide as a Good Corporate Citizen
    As a good corporate citizen, the KOEI TECMO Group complies with all laws and regulations in every country and region where it conducts business. By giving full consideration to local social conditions and acting in accordance with local customs, we make continuous efforts to be regarded as a necessary member of the relevant country or region. We deepen our understanding of the society and culture of each country where we provide our products and services, accurately identify their needs, and develop products and services that are of value to them. In addition, by delivering products created at our bases around the world to the global market, we play a part in fostering cultural exchange across the world.

• Protection of Information, Intellectual Property, and Assets

  • Respect for and Protection of Intellectual Property
    The KOEI TECMO Group respects its own intellectual property rights as well as those of others, including copyrights, patents, trademarks, designs, and trade secrets. Through the protection of the KOEI TECMO Group's intellectual property rights, we strongly encourage the original and creative research and development of our employees, and make continuous efforts to enhance the value of original content. We also work continuously to avoid infringing upon the intellectual property rights of others.
  • Protection of Information
    The KOEI TECMO Group recognizes that information is an important asset, and works to make use of valuable information for its business while properly managing confidential business information. We strive to prevent confidential business information from being improperly disclosed to or leaked to third parties in a manner that would cause loss to the business of the KOEI TECMO Group. Group Employees shall handle confidential business information carefully in accordance with internal regulations and shall use it only within the scope approved by the company.
  • Appropriate Management of Personal Information
    The KOEI TECMO Group recognizes the importance of personal information, complies with laws and regulations concerning the protection of personal information, and manages it appropriately. We handle personal information in a clear, fair, and secure manner in its collection, storage, and use, and shall not obtain information through improper means.
  • Ensuring Information Security
    The KOEI TECMO Group recognizes that information assets are an important management resource for the Group and ensures their security. We comply with laws and regulations and internal rules concerning information security, and take appropriate measures to prevent incidents such as unauthorized access, information leaks, and internal misconduct. Group Employees shall use information assets appropriately and only within the scope of their business purposes, and shall promptly report any accident or misconduct in accordance with internal regulations.
  • Appropriate Information Disclosure
    The KOEI TECMO Group complies with laws and regulations concerning information disclosure and discloses information promptly and appropriately.
  • Prohibition of Insider Trading
    Group Employees shall not buy or sell shares or bonds based on undisclosed material facts concerning the KOEI TECMO Group or its business partners, nor shall they disclose or leak such undisclosed information to others.
  • Accurate Accounting and Recordkeeping
    In order to satisfy legal requirements and protect shareholder value, the KOEI TECMO Group accurately records and reports its financial condition. We shall not falsify, conceal, or make false reports or entries regarding any transaction, nor shall we omit any description of the substance of a transaction. Regardless of the amount involved, we record all transactions and describe their true and fair value in detail.

• Responsibility to Society and the Environment

  • Elimination of Anti-Social Forces
    The KOEI TECMO Group takes a resolute stance against anti-social forces that threaten the order and safety of civil society, and maintains no relationship with them whatsoever. We firmly refuse any unreasonable demands.
  • Environmental Protection
    The KOEI TECMO Group regards environmental issues as matters to be addressed as a member of society, and strives to reduce the environmental impact of its business activities.
  • Proactive Social Contribution Activities
    Recognizing its role as a member of society, the KOEI TECMO Group is always mindful of contributing to society's development and advancement, and actively engages in social contribution activities such as promoting academic research, contributing to local communities and society, and providing disaster relief support.