1. Introduction

In order to achieve the Z Holdings Group's mission and vision, the Z Holdings Group's Code of Conduct sets forth the standards required of all officers and employees of Z Holdings Corporation and its consolidated subsidiaries and affiliates (hereinafter collectively referred to as "Officers and Employees"), in accordance with its Charter of Corporate Behavior.

2. Commitment to compliance and ethical conduct

We abide by all laws and regulations, and practice ethical conduct that lives up to the trust provided by society.

3. Respect for basic human rights

• ･We respect the rights of individuals and do not tolerate discrimination or disadvantageous treatment on the basis of political beliefs, ideology, religion, gender, gender identity, sexual orientation, physical
  characteristics, disease, age, nationality, race, ethnicity, etc.
• ･We understand and respect the culture and customs of the countries and regions in which we operate, and act accordingly.
• ･We prohibit all forms of forced labor and child labor in accordance with laws and regulations.

4. Ensuring a safe, healthy and harassment-free work environment

• ･We do not tolerate sexual harassment, abuse of authority, or any other form of workplace harassment.

• ･We comply with laws and regulations concerning occupational safety and health, give consideration to the physical and mental health of our employees, and strive to ensure a safe and healthy work environment.

5. Responsibility to customers

• ･We comply with the applicable laws and regulations related to handling personal information in each market, and collect personal information from our customers in an appropriate manner in accordance with our Privacy Policy.
• ･We use the personal information we obtain within the scope of the purposes specified in our Privacy Policy, and appropriately protect, manage, and dispose of such information. In principle, we do not provide such information to any third party, except when we have obtained the consent of the customer or when permitted by applicable laws.
• ･We maintain fairness and honesty toward our customers and do not make misleading representations or engage in misleading conduct, so that our customers can use our services safely and comfortably.

6. Fair business practices

• ･We comply with the business competition laws of each market where we operate, conducting our business activities with a spirit of fair play and on the principles of free and fair competition, and do not impose unfair trading conditions on our business partners or service users.
• ･We do not obtain, or allow others to bring in, information about our competitors in an unfair manner.
• ･We comply with laws and regulations regarding imports and exports and other international trading rules.
• ･We do not engage in prohibited transactions with specified countries, regions, organizations, or individuals that are subject to economic sanctions.

7. Avoidance of conflict of interest

We act with respect for the interests of the company and do not use our position or status in the company to benefit ourselves or a third party.

8. Appropriate use and management of company assets

• ･We recognize that intellectual property rights are an important asset for the business of the Z Holdings Group and appropriately protect those rights, while also respecting the intellectual property rights of third parties.
• ･We use, manage, and dispose of company assets and trade secrets appropriately, and do not use them for any purposes other than business.

9. Thorough implementation of information security

We strictly protect and manage our information assets, including customer information and confidential information, and do our utmost to protect them from unauthorized access, leakage, falsification, destruction, etc.

10. Accurate, fair, timely, and appropriate information disclosure

• ･We create accurate and complete accounting records.
• ･We disclose accurate information to society and the stock market in a fair, timely, and appropriate manner.
• ･We strictly manage insider information and do not engage in insider trading.

11. Maintenance of proper relationships with political entities and
governmental bodies

We maintain proper relationships with political entities and governmental bodies, and do not give preferential treatment to any individual or organization that engages in political activities.

12. Prohibition on bribery and corruption

• ･We do not engage in any form of bribery, corruption, or corrupt practices, whether with public servants or private citizens.
• ･In order to ensure free and fair trade, we provide and accept business entertainment and gifts only to the extent deemed appropriate.

13. Rejection of relationships with crime

We reject any involvement with anti-social forces, Boryokudan (organized crime syndicates), and other organized criminals, as well as criminal activities such as money laundering and terrorist financing.

14. Giving back to society and protecting the environment

We actively contribute to society and protect the environment through our business activities, taking into consideration the social and environmental impact of our business activities. We encourage our Officers and Employees to take an interest in these activities, and to actively participate in and support them.

15. Consultation and whistleblowing on compliance issues, and prohibition of retaliation

• ･If we discover any improper acts or suspected compliance violations, we consult or report them to our superiors, the Compliance Consultation Desk, or the Internal Reporting Desk.
• ･We prohibit any retaliation or disadvantageous treatment towards whistleblowers regarding compliance.

16. Revision and abolition

The revision or abolition of this Code of Conduct is the responsibility of the Board of Directors of Z Holding Corporation.

*Unless otherwise specified, English-language documents are prepared solely for the convenience of non-Japanese speakers. If there is any inconsistency between the English-language documents and the Japanese-language documents, the Japanese-language documents will prevail.

Adopted April 23, 2021