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Whistleblower Policy

The Whistle-Blowing System of IK Group: a confidential channel for raising serious concerns about management or operations.

Objectives

Why This System Exists

  1. To listen to employees of each IK entity who have concerns or find issues in management or operation of the entity which are apt to be neglected internally in the entity.
  2. To strengthen the compliance structure within IK Group.
Make a Report

Whistle-Blowing Contact Window

Send your report by e-mail. You can e-mail the contact window at any time.

ikgroup-Whistle-Blowing@dtrs-hl.com
Languages
English or Mandarin Chinese (simplified characters)
Review Hours
10:00 – 17:00, Mon – Fri
Japan time, excluding holidays
Operation Flow

How a Report Is Handled

1
You
Report your concern or issue to the Contact Window by e-mail, in English or Chinese.
2
Contact Window
Communicates with you and gives notice of the report, with translation and a brief summary, to IKJ.
3
General Manager, Risk Management Office of IKJ
Reports to the President of IKJ and receives instructions.
4
IK Entity
Investigation of the concerns or issues is carried out with the IK entity concerned.
Depending on the nature or content of the whistle-blowing, an investigation may be initiated by IKJ, or only a feedback report may be given to the top management of the IK entity in question.
Scope

What This System Covers

Focus of the system

Improper bookkeeping Fraud Bribery Cartels Violation of laws Violation of significant company rules & regulations

This system is to focus on early detection of, among others, the matters above.

Not covered

Personal complaints Grievances about treatment Wages, etc.

Personal complaints or grievances about treatment, wages, etc. are not the focus of this system.

Important Notes

Before You Report

No Retaliation

You will not receive any disadvantageous treatment on the basis of your whistle-blowing itself.

Anonymous Reporting

You may make a report anonymously via an e-mail account of a non-IK entity. For appropriate operation of this system, however, it is appreciated if you would identify yourself.

Who May Use It

Officers, employees, part-time or temporary employees, and all people working for an IK entity, irrespective of employment status. It is not available to those not employed by an IK entity (e.g. outsourcing companies, customers, your family or neighbors).

Language & Hours

Reports are accepted only in English or Mandarin Chinese (simplified characters) and are reviewed from 10:00 to 17:00, Monday through Friday (excluding holidays), Japan time. You can e-mail the contact window at any time.

Automatic Reply

An automatic reply will follow your whistle-blowing e-mail. If you do not receive it, please check your spam settings or try another e-mail account.

Parallel Systems

This system is operated in parallel with any whistle-blowing system or the like already implemented, or to be implemented, in each IK entity.

Reports in Japanese

Japanese-Language Points of Contact

If you make a report in Japanese, please e-mail any of the following points of contact. No automatic reply follows.

NameE-mail
Outside Counsels
Mr. Seigi Nakagawaskyblue@justice-nakagawa.com
Ms. Makiko Gotom.goto.54@hik-lo.jp
IKJ Human Resources
Ms. Yasuko Suitosuito.hotline@inabata.com
Mr. Nobuhiro Takemototakemoto.hotline@inabata.com
IKJ Legal
Mr. Takashi Banban.hotline@inabata.com
IKJ Internal Audit
Mr. Kensaku Oyamaoyama.hotline@inabata.com
Audit and Supervisory Committee
Mr. Nobukazu Kuboikuboi.hotline@inabata.com

Special Note for EU Subsidiaries

Subsidiaries located in EU member states are not included in this whistle-blowing system, so as not to conflict with the restrictions on the transfer of personal information under the General Data Protection Regulation (GDPR) laid down by the EU. Therefore, employees of such subsidiaries cannot make a whistle-blowing report through the channels described herein.

Source: Whistle-Blowing System of IK Group