Compliance

To foster values that shape our corporate culture, we have established the KPP Group Charter as the guiding principle for all decision-making, placing compliance with laws and regulations at its core. We view compliance not simply as meeting legal requirements, but as an ethical standard that reflects our responsibility as a corporate citizen, enabling us to respond to the evolving expectations of society. In addition, in 2025, the Company formulated an Anti-Corruption and Bribery Policy, as outlined below, following a resolution by the Board of Directors. The Company ensures thorough compliance with the Anti‑Corruption and Bribery Policy across the entire organization by communicating the policy to all officers and employees and conducting regular training programs. This policy will continue to be reviewed as necessary under the supervision of the Board of Directors.

The KPP Group is committed to upholding the highest standards of integrity and ethics in all of its business activities. The Group will not tolerate any conduct that violates domestic or international anti-bribery laws and regulations, including compliance with the Penal Code and the Unfair Competition Prevention Act of Japan, the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, the EU Whistleblower Protection Directive, France’s Sapin II Law, and the relevant anti-bribery and corruption legislation and regulations in Australia, New Zealand ,South-East Asia and East Asia.
Through various systems, initiatives, and actions established under this Policy, we strive to prevent corrupt practices, such as bribery, money laundering, and illegal demands from or to public officials or business partners.

1.Compliance with Laws and Social Norms
All officers, employees, and stakeholders are required to comply with applicable anti-corruption laws, regulations, guidelines, and other social norms in each country and region in which the Group operates, in addition to adhering to the Group's internal policies and regulations.

2.Prohibition of Corruption
(1)The Group strictly prohibits any form of bribery, including facilitation payments. Employees shall not directly or indirectly offer, promise, or provide bribes to public or government officials in any jurisdiction. Additionally, we do not tolerate any type of corrupt practices such as money laundering, obstruction of justice, or improper demands related to insider trading.
(2)All business partners, both domestic and international, must be treated with fairness and equity. Offering or accepting gifts, business entertainment, or other economic benefits beyond social courtesies is prohibited unless expressly allowed by internal policies or local legislation. This prohibition extends to excessive entertainment intended to influence the conclusion of business agreements.

3.Record Keeping and Retention
The Group requires that all transactions involving money or other benefits given to third parties during the course of business activities be fully and accurately documented in the Group’s accounting records. Such transactions must be recorded under appropriate headings and retained in accordance with internal regulations. Detailed records and receipts must also be maintained for any payments related to service fees and charges to business partners, including contractors and directors.

4.Education and Training
To ensure compliance and foster a culture of integrity, the Group will provide ongoing education and training on anti-corruption laws and business ethics. This Policy shall be communicated to all officers and employees, with periodic training sessions designed to inform them of the latest anti-bribery laws, regulations, and guidelines relevant to the Group’s operations.

5. Whistleblowing System
The Group has established a secure, independent third-party reporting system that allows officers, employees, and external parties to report any actual or potential violations of laws and regulations related to anti-corruption. This system is designed to protect the confidentiality of the whistleblower and to operate in a manner that protects whistleblowers from any form of retaliation or disadvantage.

6. Measures Against Violations
Any officer or employee found to be in violation of this Policy, including engaging in acts that contravene anti-bribery laws and regulations – whether domestic or international – will face strict disciplinary action. Disciplinary measures will be taken in accordance with the relevant laws, regulations, and the Group’s internal policies and procedures.

7. Continuous Improvement and Review
The Group is committed to continuously improving its anti-corruption efforts. This Policy will be reviewed and updated as necessary to ensure its alignment with current laws, regulations, and best practices in anti-bribery and corruption prevention.

8. Compliance Responsibility
The Group takes full responsibility for ensuring compliance with anti-corruption laws and regulations, as set forth in this Policy. All officers, employees, and relevant stakeholders are expected to adhere to these standards and contribute to the Group’s efforts to prevent corruption and bribery in all its operations.

Our compliance framework is designed to ensure strict adherence to laws and ethical conduct, and consists of several key elements. Through initiatives below, the KPP Group strives to build corporate credibility and achieve sustainable growth.

1.Compliance Committee
We have established a Compliance Committee to conduct compliance training, promote awareness of internal and external reporting channels, and review responses to compliance-related issues.

2.Internal Reporting Channels (Whistleblowing system)
To enable swift action in the event of a compliance violation, we have set up an internal reporting channel managed by the Compliance Committee Secretariat and an external channel operated by an independent third party. These channels provide employees and business partners with a secure environment to consult or report concerns.

3.Shared Commitment to Legal Compliance
We actively foster a shared commitment to legal compliance across the organization, promoting a strong culture of compliance at every level.

4.Strengthening Governance Systems
To ensure management efficiency, transparency, and soundness, we are committed to establishing and enhancing a robust corporate governance framework.

To prevent, detect early, and respond promptly and effectively to compliance violations, we have introduced a whistleblowing system that ensures confidentiality and anonymity.
The system provides both internal and external reporting channels.
Matters subject to reporting include violations of laws and regulations (such as acts in violation of the Antimonopoly Act, the Act on the Promotion of Fair Trade, and corrupt practices including bribery), accounting irregularities, inappropriate use of expenses, as well as various forms of harassment, including power harassment and sexual harassment. Through this system, employees, business partners, and their family members are able to seek advice or report compliance violations. In addition, our internal rules clearly stipulate that whistleblowers will not be subject to any disadvantageous treatment as a result of making a report.
Through these initiatives, we aim to achieve highly transparent corporate management.

・Number of Whistleblowing Reports and Consultations

Item	FY2022	FY2023	FY2024
Number of whistleblowing reports and consultations	4	5	8

・Anti‑Corruption‑Related Information

Item	FY2024
Number of employee dismissals due to violations of the Anti‑Corruption Policy (cases)	0
Fines, penalties, and settlement amounts related to corruption (JPY)	0
腐Provisions for corruption‑related fines and settlements (JPY)	0

・Amount of Political Contributions

Item	FY2022	FY2023	FY2024
Political Contributions (thousand yen)	0	0	0

When a report is received, the Compliance Committee assigns the investigation and response to the relevant department based on the nature of the issue. Any matter deemed significant by the Committee is immediately reported to the Board of Directors. For issues requiring a broader perspective, the Committee promptly conducts a thorough investigation and recommends measures to prevent recurrence. In the event of a serious compliance incident, we will act swiftly to disclose information to the public, fulfill our accountability obligations, identify the root cause, and implement strict corrective measures to prevent recurrence.