MIXI GROUP
BUSINESS CONDUCT GUIDELINES

We provide high-quality services responsibly and work to prevent problems in our services to ensure that they can be enjoyed with peace of mind.

Provision of safe and secure services
・We work to improve the quality and added value of our services to provide safe and secure services.

Consideration for and protection of customers
・We pay due attention to the possibility that our services may have various impacts on our customers and focus on addressing any potential impacts.
・We are aware that our business activities have an impact on younger people and conduct activities to protect them.
・We work together with various industry groups such as organizations related to social media and games to prevent problems and fraud for the protection of our customers.
・We prevent criminal acts that illegally use our services through monitoring and a patrol system.

Solving social issues through our services
・We work to resolve social issues, such as by reducing isolation through communication services, by providing services unique to MIXI Group that enrich the lives and cultures of our customers.

We recognize the value of intellectual property and new solutions and work to create innovative services while adhering to ethics.

Cultural renewal
・We aim to promote innovative development through our business activities, striving to refresh and revitalize culture, and to create new services.
・We strengthen cooperation with stakeholders to have a positive impact on people and society through innovation.

Respecting, utilizing and protecting intellectual property
・We recognize the importance of intellectual property. We thoroughly protect and manage the intellectual property of MIXI Group and do not unreasonably infringe or misuse the intellectual property of third parties.
・We actively and effectively utilize the intellectual property of MIXI Group.

Promotion of innovation
・We strive to provide services that actively utilize new solutions in order to remain at the forefront.
・We recognize the usefulness of data and other intangible assets, and promote innovation through effective and proactive utilization.

Ethical use of AI
・We strive to provide reliable services based on a thorough understanding of the risks inherent in AI and an appropriate understanding of the risks when AI is used.
・We use AI in a fair and transparent manner and show appropriate accountability to stakeholders.

We value our connection with customers. We not only create innovative services by promoting innovative development, but also identify issues based on customer feedback and promote the provision of services aimed at solving them. We strive to communicate with our customers in good faith and provide them with information promptly to achieve the above.

Integrity in communication with customers
・We maintain a fair relationship with our customers.
・We value integrity in communication with our customers and strive to reflect their feedback in the improvement and development of products to ensure the quality and safety of our services.
・We aim to create social value together with our customers by effectively utilizing their feedback.

Prompt response to customers
・We respond to customer inquiries promptly and with integrity.
・We aim to adequately resolve the problem from the customer’s standpoint with integrity.
・We strive to provide important service and event information in a timely and easy-to-understand manner so that customers can make the right choices.

Provision of value to customers
・We aim to have a high awareness of the value we would like to provide customers and provide highly satisfying services and events.
・We proactively work on an individual level to provide MIXI Group services that enrich the lives and cultures of our customers.

We build and maintain proper business relationships through business activities that are conducted with fairness and integrity. We adhere to relevant laws and regulations as well as internal rules, avoid engaging in activities that conflict with the interests of the company and maintain sound and transparent relationships with political and administrative bodies.

Compliance
・We comply with all relevant laws and regulations as well as internal rules, including ethical regulations. We do this by gaining a thorough understanding of laws, regulations, customs, reason, ethics and all other social norms and the spirit embodied in them, and enhancing our knowledge related to compliance.
・We call on our business partners to actively embrace compliance throughout our business activities.

Prohibition of bribery
・We comply with all laws and regulations in respective countries and regions, including the U.S. Foreign Corrupt Practices Act and the United Kingdom Bribery Act 2010, and do not engage in bribery or any other forms of corruption.
・We do not provide civil servants or private business partners with dishonest monetary payments or other valuables for the purpose of benefiting MIXI Group in the conduct of its business, nor do we make any contacts that could be misunderstood as inappropriate relationships.
・We appropriately report any provision of hospitality or gifts as allowed by social customs in accordance with internal rules.

Fairness and integrity in transactions
・We value fairness in our relationships with business partners.
・We do not make unreasonable demands of our business partners or delay payments. We comply with relevant laws and internal rules and conduct business in good faith.
・We do business fairly and maintain transparent relationships with our business partners.

Prohibition of conflicts of interest
・We make a clear distinction between public and private interests to ensure that there are no conflicts of interest between individuals and the company.
・We work to avoid conflicts of interest between individuals and the company by immediately reporting the situation to a superior and following the superior’s directions.

Compliance with competition laws
・We conduct business in compliance with the competition laws applicable in the countries and regions in which we operate.

Prevention of insider trading
・We do not engage in insider trading or other suspicious activities, such as stock trading, either on our own or through a third party using any undisclosed information of MIXI Group or a business partner that we have obtained in the course of business.
・We comply with the trading restrictions stipulated in internal rules and other relevant regulations when trading MIXI Group shares or engaging in other trading activities.

Dealing with antisocial forces
・We do not have any relationship with antisocial forces or organizations, including business relationships.
・We resolutely reject unreasonable demands from antisocial forces and organizations.
・We do not engage in money laundering or any activities suspected of providing benefits to antisocial forces and organizations.

Relationships with political parties and administrative bodies
・We build sound and transparent relationships with political parties and administrative bodies.
・We report to the relevant department in advance and obtain approval before engaging in any political activity that takes place during working hours or in or around the office.

We strictly manage and protect the confidential information of MIXI Group, our business partners, customers and employees through the proper handling of information assets. We do this by raising awareness of relevant domestic and overseas laws and regulations, as well as internal rules, and implementing sufficient measures to maintain the trust of our stakeholders.

Preservation and proper use of information assets
・We thoroughly understand that the information of MIXI Group as well as the information the group receives from third parties must be strictly managed as important assets of the company.
・We implement thorough security measures for management of information assets in accordance with MIXI Group policies and internal rules to prevent information leaks.

Cybersecurity
・We are aware of the risks posed by cyberattacks and the extent of their impact, and all employees of MIXI Group individually take measures to ensure strong cybersecurity.
・We implement measures necessary for early response, quick recovery and appropriate information collection to prepare for the possibility of damage from cyberattacks.

Protection of personal information
・We securely retain the personal information of our customers, business partners and employees.
・We strictly manage personal information in accordance with relevant domestic and international laws and internal rules to protect privacy.
・We do not use personal information obtained in the course of business for private purposes.

Maintenance of confidential information
・We protect MIXI Group’s confidential information as a company asset and strictly manage the information as confidential.
・We obtain any confidential information of a third party from the rights holder. We manage the information obtained in accordance with a contract or specified agreement.

We respect fundamental human rights in accordance with international human rights standards. We also protect human rights by prohibiting discrimination and respecting the right to privacy. We respond appropriately to any problems that arise and protect affected persons to ensure their human rights are upheld.

Respect for international human rights standards
・We conduct our business activities with respect for international human rights standards, including the ILO’s Declaration on Fundamental Principles and Rights at Work.

Protection of human rights
・We respect the fundamental human rights of all people and do not violate the dignity of the individual.
・We monitor for any negative impact on human rights caused by our business activities, prevent the occurrence of such an impact and respond and make improvements if such an impact is found.
・We implement appropriate remedial measures in the unlikely event that human rights issues arise.

Compliance with human rights policies and prohibition of discrimination
・We declare and adhere to MIXI Group’s policies on respect for human rights.
・We do not discriminate based on race, ethnicity, nationality, language, religion, gender, physical characteristics or for any other reason.
・We also call on our business partners to respect human rights and prohibit discrimination.

We create a culture that allows the various individuals of our workforce to speak freely and develop their careers by promoting diversity, equity and inclusivity both inside and outside MIXI Group.

Promotion of diversity, equity and inclusivity
・We improve creativity and organizational performance by mutually enhancing each other through accepting diverse opinions and values.
・We cultivate a culture that allows staff with a wide array of backgrounds to interact as equals and recognize each other’s value.
・We value the provision of equal opportunities based on individuals’ standpoints and differences in living circumstances.

Human resource development
・We as individuals acquire skills and experience that lead to our growth by performing duties with integrity and actively fulfilling our roles.
・We as individuals strive to develop our careers and abilities autonomously and proactively by using internal systems so that we can actively leverage our uniqueness and abilities.
・We create an environment where ambitious and skilled members share knowledge and support each other to grow.

Promotion of work-life balance
・We aim to create a comfortable working environment for all employees where we recognize flexible work styles and promote the establishment and dissemination of relevant systems.
・We establish an environment where employees in various situations, including those who provide childcare or eldercare or those who are undergoing medical treatment, can play an active role while maintaining a healthy work-life balance.
・We make every effort to eliminate long working hours and avoid unhealthy practices, as well as prioritize the recovery of employees in the case that their health is compromised.

Health and safety / prohibition of discrimination and harassment
・We strive to maintain safe and healthy working conditions, which form the basis of a diverse working environment.
・We create a working environment that does not tolerate any form of harassment under any circumstances.

We inform stakeholders of our activities accurately and listen to their opinions to increase corporate value through two-way communication.

Promotion of dialogue with stakeholders
・We listen to stakeholders’ opinions and strive to have constructive dialogue with them.
・We strive to provide accurate information by ensuring that financial information is recorded in accordance with appropriate accounting standards and relevant laws and regulations.

Disclosure of information to stakeholders and establishment of trusting relationships
・We strive to actively disclose not only financial but also non-financial information to stakeholders in order to facilitate a more accurate understanding of MIXI Group.
・We value two-way communication with stakeholders and strive to further gain support and approval for our corporate activities.

Timely and appropriate information disclosure
・We disclose information necessary for stakeholders, with integrity in a timely, appropriate and easy-to-understand manner.
・We disclose information related to MIXI Group, with integrity and fairness in accordance with relevant internal rules.

We value that we are members of our local communities. We actively contribute to the local communities and place importance on our connections with them.

Significance and purpose of community contribution activities
・We deepen the connection with local communities through our community contribution activities and strive to meet social needs.
・We build trusting relationships with local communities through our community contribution activities.

Connection with local governments and communities
・In order to contribute locally, we promote cooperation with local governments, communities and groups based on trusting relationships built through our business activities.

We take responsibility for confronting environmental issues and are highly conscious in our efforts to reduce environmental impacts in order to achieve a sustainable society.

Reduction of environmental impacts in business activities
・We work to reduce environmental impacts by streamlining and rationalizing our business activities to curb the consumption of resources and energy.
・We support international initiatives against climate change and promote the achievement of a sustainable society.

Environmentally-conscious work attitude
・We, as individual employees, work to be aware of the effective use of resources and energy as we carry out daily tasks.

MIXI Group regularly prepares for emergencies, with a risk management system in place to address crises and risks in a prompt manner.

Establishment of a crisis management system
・MIXI Group has in place a practical governance system for attaining sustainable growth and higher corporate value.
・MIXI Group has a risk management system to prevent, detect and address risks in order to prepare for crises and risks.
・MIXI Group prepares for the continuation and recovery of business activities on a regular basis so that we can fulfill our social responsibility in the event of an emergency.
・If, due to a violation of these Guidelines, a societal loss of trust or the potential thereof is recognized, top management will take initiative and assume responsibility in resolving the problem, investigating the cause, and preventing reoccurrence.

Establishment of an internal reporting system
・MIXI Group has a contact point to receive reports and offer consultation regarding violations of laws and regulations, improper acts and the possibility of such misconduct.
・MIXI Group strictly protects the privacy of the reporter and other concerned parties and keeps the content of the report strictly confidential.
・MIXI Group ensures that the reporter is not subjected to unfair treatment, such as a negative change in their working environment or dismissal.