Compliance Basic Policy

The basic policy of compliance for our Group is as follows:

Our Group considers it absolutely essential to adhere to laws, corporate ethics, and other regulations as we fulfill our social responsibilities through business activities. The Legal Affairs Officer, responsible for overall legal affairs, is positioned within the Corporate Management Headquarters of Kitahama Capital Partners Co., Ltd., and the Compliance Department of San Asset Management Co., Ltd., working closely with each department to strengthen compliance. For important legal matters, we seek opinions from legal advisors and conduct legal checks on all corporate activities.
Our Group also takes a firm stance against any anti-social forces that threaten public order and safety. We will not provide any benefits under any pretext and will avoid any involvement with anti-social forces. We also continually check whether stakeholders are involved with anti-social forces, and when necessary, consult with various investigation agencies or collect information.

Basic Policy on Response to Anti-Social Forces

To maintain public trust and ensure sound corporate management, we establish the following basic policy to firmly reject and sever ties with anti-social forces that threaten social order and safety through unreasonable demands:

(1) Severing Relationships Including Transactions
We will take a firm stance against unreasonable demands from anti-social forces and work to sever any relationships with them.
(2) Prohibition of Financial Support
Under no circumstances will we provide financial support to anti-social forces.
(3) Collaboration with External Expert Organizations
To eliminate anti-social forces, we will maintain close collaboration with external expert organizations such as the police, lawyers, and anti-violence organizations.
(4) Organizational Response
The response to anti-social forces will not be left to individual staff or departments alone; the organization, including top management, will respond collectively.
(5) Legal Measures in Civil and Criminal Cases
If an unreasonable demand is made by anti-social forces, we will actively consult with external experts and take all possible legal measures in civil matters, and will not hesitate to pursue criminal action.