The purpose of this policy is to establish an organizational structure and other measures to eliminate any and all relations between antisocial forces and the Company.
Article 2 (Definition)
In this Policy, “antisocial forces” shall mean people or entities who fall under any of the following categories or those for whom five years have not passed from the date when their involvement with the antisocial forces ended.
① Criminal Gangs, commonly referred to as gangsters, as stipulated in Article 2, Item 2 of the "Act on the Prevention of Unjust Acts by Criminal Gang Members" (hereinafter referred to as the "Criminal Gang Countermeasures Law") of the British Virgin Islands.
② Criminal Gang members (meaning the gangsters stipulated in Article 2, Item 6 of the Criminal Gang Countermeasures Law) of the British Virgin Islands.
③Associate Members of Criminal Gangs (i.e. people under a certain level of control by a Criminal Gang, who might commit violent illegal acts supported in some way by the power of the Criminal Gang, or supply funds, weapons, etc. to the Criminal Gang or its members, etc. Those who cooperate in the maintenance or operation of a Criminal Gang, but are not themselves a member of the gang)
④Companies related to Criminal Gangs (i.e. companies in which gangsters are substantially involved in their management, or companies that are largely managed by quasi-members of a gang or former gangsters, and actively support or maintain a Criminal Gang, such as by providing funds to gangsters. (A company that cooperates with or is involved in the activities of a Criminal Gang, or that actively makes use of gangsters in the execution of its business and/or cooperates in the maintenance or operation of a Criminal Gang.)
⑤ Corporate Extortionist (meaning those who might engage in violent, disruptive or illegal acts, to obtain unfair profits or benefits for other companies, which might threaten the lives and safety of ordinary citizens.)
⑥ Fraudulent Social Movements, etc. engaged in racketeering type activities (meaning people or organizations who might engage in violent or illegal acts to obtain unfair profits or benefits by disguising as or falsely claiming to be social movements or political activities, which might threaten the lives and safety of ordinary citizens.)
⑦ Specially Classified Racketeering Groups (People or groups other than those listed in the preceding items, who engage in violent or illegal acts similar to, in cooperation with, or using the power of Criminal Gangs, and operate through their relationships or financial connections with gangsters.)
⑧ Other equivalents to the preceding categories (meaning companies, groups, and individuals who are found to be involved in any of the above.)
Article 3 (Basic Policy for Dealing with Antisocial Forces)
1. The Company will formulate the following "Basic Policy for Dealing with Antisocial Forces" and disseminate it internally.
2. The Company will respond to unreasonable demands from antisocial forces as a whole organization, without leaving it to the individual person or department in charge of the matter and ensure the safety of the officers and employees who respond to antisocial forces.
3. To be prepared in the event of receiving any unreasonable demands from antisocial forces, the Company will build and maintain close and cooperative relations with specialized outside agencies such as police and lawyers.
4. The Company will block all relationships with antisocial forces, including business relationships, and reject any unreasonable demands they might make.
5. All unreasonable demands made by antisocial forces will be addressed from the perspective of both civil and criminal law.
6. Even if the unreasonable demands made by antisocial forces are a form of blackmail due to a scandal related to the Company’s business activities or the private activities of our officers and employees, we will never make a backdoor pay-off or transaction to conceal the matter. The Company will never provide any funds to antisocial forces.
Article 4 (Target Persons)
Without exception, all of the Company’s officers and employees must comply with this policy regarding our response to antisocial forces.
Article 5 (Prevention of Transactions with Antisocial Forces)
1. In order to prevent transactions with antisocial forces, the Company will promote the inclusion of gang exclusion clauses in all the contracts into which it enters.
2. Contracts refer to agreements related to all the Company’s transactions, both temporary and continuous, including system usage contracts, business consignments, hiring of employees, etc. Contracts are not limited to individuals but shall include groups, companies, etc.
Article 6 (Investigation Before the Start of Transactions)
Prior to a transaction being made for the first time, it shall be examined to determine whether the Company’s business counterpart is itself, or is involved with, an antisocial force.
Article 7 (Prohibition of a Contract)
If, as a result of the preliminary investigation prescribed in the preceding article, a contractual counterpart or business associate is found to be, or be involved with, an antisocial force, the contract shall not be concluded.
Article 8 (Investigations During the Transaction Period)
1. The Company shall endeavor to regularly examine our business associates for any involvement with antisocial forces.
2. In addition to what is provided for in the preceding paragraph, if there is a suspicion that a business associate is, or is influenced by, an antisocial force, an investigation must be conducted to determine whether or not such antisocial force membership or influence in fact exists.
Article 9 (Elimination of Antisocial Forces by Contract Cancellation)
1. If, as a result of an inspection as prescribed in the preceding articles, it is found that the other party to the contract is, or is involved with, an antisocial force, the contract will be cancelled, even after it has been concluded.
2. When a contract is being cancelled, the head of the Company’s department in charge of it shall consult in advance with the head of the counterpart’s corresponding department, and also fully discuss the matter with a lawyer or other specialized outside agency to determine the best course of action.
3. To the extent possible, the Company will regularly check and appropriately manage shareholder information, including stock trading status and other shareholder related information.
Article 10 (Cooperation with Specialized Outside Agencies)
In the event of a dispute with an antisocial force, the Company shall endeavor to prevent the damage caused by the act by promptly contacting and consulting with a lawyer, the police or other relevant outside agencies or organizations.
Article 11 (Information Collection)
Centered on the relevant department, the Company shall endeavor to collect information on antisocial forces.