Compliance Code of Conduct

The environment surrounding companies has experienced a rapid change, and the public has been trying to scrutinize whether companies comply with corporate ethics and legal compliance. Compliance is essential to win the trust of customers and other stakeholders, and without compliance a company will not be able to start business activities.
We hope that all board members and employees will fully confirm the contents of this Compliance Code of Conduct and various regulations and cooperate in creating JBS that is trusted by customers.

December 1, 2019
Japan Business Systems, Inc.
President Yukihiro Makita

We will respect our customers and engage enthusiastically in our business so that they can enjoy a great experience through our products and services. We will always strive to maintain fairness and integrity in dealings with customers, and will not engage in transactions that are unfair or deceptive, and will sincerely observe our promises to customers.

1. Bearing in mind at all times that providing high-quality products and services is the source of customer confidence, we will give top priority to ensuring the quality of our products and services, and will conduct strict quality control.
2. We will understand customer complaints, opinions, and requests accurately and respond quickly and sincerely.
3. When providing new products and services, we will sufficiently make sure that they are useful to society and that there are no problems with security. In addition, when we receive information related to the safety of our products and services, we immediately contact the relevant departments to confirm the facts and take prompt and appropriate action when a problem is identified.
4. When promoting our products and services to other parties through sales activities, advertising, sales promotion and others, we comply with the Unfair Competition Prevention Law and other relevant laws and regulations, and provide customers with useful and accurate information.
5. We will strictly manage customer information obtained through the conclusion of contracts with the utmost care to prevent the leakage of such information.

We will always observe laws and regulations and act in a fair and ethical manner in the course of our business activities. Decision-making in our business activities is based on the best interests of the Company and does not tolerate any form of corruption, such as bribery, or excessive gifts and entertainment. We compete fairly with other companies to provide better services to customers.

1. In conducting business transactions, we will fully recognize that all suppliers and third-party vendors are equal partners to us and respond to them fairly and sincerely.
2. We will not provide or promise to provide any money, goods, excessive service, gifts, entertainment or other benefits to government agencies, public officials or equivalent persons.
3. Providing and receiving of gifts and entertainment with suppliers and third-party vendors must be reasonable and appropriate under socially accepted norms. We will not provide customers with excessive gifts or entertainment that exceed standards of reasonableness and appropriateness under socially accepted norms.
4. Our directors, officers and employees will act for the Company’s best interests in the performance of their work, and will not, or will not appear to, prioritize their personal interests to the interests of the Company.
5. We will not recognize any anti-social organizations or individuals, and will not be directly involved in activities that may promote or contribute to such organizations or individuals. We will take a firm stance against malicious acts committed by anti-social forces.
6. We will respect fair and free transactions and comply with laws that ensure fair competition, such as the Antimonopoly Act and the Subcontract Act. In particular, we will strictly refrain from discussing with competitors terms and conditions proposed or submitted to customers, or exchanging information therewith.

We provide workplaces free of harassment and discrimination in order for each employee to perform their work with peace of mind and to exercise their full potential.

1. We will observe all applicable labor-related laws, standards, guidelines, and regulations, and create a workplace environment in which everyone can work with peace of mind.
2. We will respect each other in the workplace, and build a corporate culture of mutual respect to be considerate to all stakeholders.
3. We will not tolerate any form of discrimination, harassment, slander, coercive behavior, bullying, aggressive or dishonorable behavior, and will strive to maintain a working environment in which all employees can make the most of their capabilities.
4. We prohibit any behavior that could lead to discrimination, harassment and the like in communications with our customers, suppliers, and other stakeholders.
5. We will respect diversity and treat everyone impartially and fairly. We will provide equal opportunities to employees and applicants, and ensure that any employment decisions are made irrespective of the attributes protected by law, such as race, religion, nationality, age, disabilities, gender, pregnancy, or sexual orientation.
6. We will respect each other's privacy among our directors, officers and employees. We will treat their personal information that we have learned in the course of our work in strict confidence, and will not disclose it to other directors, officers or employees as well as to the outside of the Company.

We will abide by the basic rules that we must observe as a corporate employee, so that we can be proud of the fact that we are directors, officers or employees of the Company. In addition, in the course of business operations, we will appropriately manage the records, information, assets, and the like of the Company and will not engage in any improper conduct.

1. We will faithfully fulfill our promises to customers. Each individual will not promise to do anything beyond his or her authority.
2. We will report, consult, and communicate accurately and honestly in the course of our business operations.
3. We will have a strong sense of responsibility and a sense of mission in performing any work. In the event of a problem, we will respond sincerely and not try to escape from responsibility.
4. In the event of any violation of rules, misconduct, or any acts likely to lead to the violations or misconducts within the company, each individual must immediately notify the superior or the internal reporting office (Compliance Committee), without turning a blind eye.
5. We will accurately maintain records and make reports during the course of business operations. We will manage business records in accordance with our rules for document management.
6. Based on accurate records and reports, we will make accurate reimbursement of business expense, and will not commit any fraudulent acts, such as charging fictitious expenses.
7. We will utilize the assets owned by the company properly. Each individual must not use the company's assets for any purpose other than legitimate business purposes, and in particular must not use such assets for the purpose of pursuing individual profits.
8. We will appropriately manage confidential information held by the Company and prevent the leakage of trade secrets to any third parties. We will not use confidential information of the Company that we have come to know in the course of our business for our own personal benefit or for the personal benefit of any third party.
9. We must be aware that we retain and use the personal information of customers, business partners, employees, or others, and will comply with the Personal Information Protection Law and other laws and regulations, and will appropriately acquire and use the personal information. We will appropriately manage the personal information we receive and manage it so that it will not be leaked or falsified.
10. As a good corporate citizen with a high standard of ethics accepted in the international community, we contribute to the development of the economy and society at home and abroad.

1. The Code of Conduct applies to all directors, officers and employees (including full-time employees, part-time/temporary employees, contract employees, temporary employees) of the Company and its subsidiaries.
2. Any violation of the Code of Conduct may be subject to disciplinary action in accordance with the working regulations.
3. The Legal and Compliance Section of the General Affairs Department will administrate this Code of Conduct. If you have any questions about the details, please contact the department.