Compliance

Based on the recognition that not only compliance with laws and regulations but also taking appropriate actions in line with social norms is a prerequisite for all corporate activities, directors, corporate officers, and partners of the Company Group (as well as personnel with equivalent duties) shall lead efforts to ensure thorough compliance by the Company Group from a groupwide perspective. A compliance officer designated by the President shall supervise overall initiatives for the Company Group's compliance.

The Company has established basic principles regarding its engagement with compliance and created compliance regulations with the aim of ensuring thorough compliance within the organization. Based on these regulations, the Company has developed structures and initiatives to actively promote compliance.

Additionally, the Internal Audit Division audits and reports the status of the Company Group's compliance with laws and regulations to the President, the Board-Audit Committee, and, as necessary, the Board of Directors. The audited departments and subsidiaries shall promptly address any issues that need to be corrected or improved.

An internal reporting hotline has been established and is operated as a means for officers, employees, and others at the Company Group to directly provide information to the Company regarding conduct that is in violation of, or risks violating, laws and regulations.

Efforts to Prevent Harassment

The Company believes that fostering mutual respect for human rights and dignity and striving to eliminate discrimination and harassment from society with all connected parties, including directors, officers, employees, members of portfolio companies and investment candidates, clients, and business partners, is essential for achieving sustainable corporate growth and fulfilling its social responsibility.

Harassment is an unacceptable act that unjustly harms the dignity and character of an individual. Not only does it disrupt workplace order and environment, impairing work performance, but it also damages the social reputation of the Company and may hamper the development of the private equity industry. In the context of investment in unlisted securities, which forms the core of the Company's business, the relationship between investor and investee may give rise to power imbalances. Harassment in the workplace as well as harassment towards members of portfolio companies and candidates for investment fundamentally undermine trust in our business and are completely unacceptable. As a responsible business entity, the Company is committed to establishing a work environment where each individual is respected, can work safely, and can fully express their enthusiasm and abilities, and it will uphold the human rights of all associated stakeholders, conducting business with high ethical standards.

The Company aims to identify and address compliance issues and human rights violations at an early stage.

All of our stakeholders, including our executives and employees (including contract employees, dispatched employees, etc.), former executives and employees, prospective employees, members of portfolio companies, investment candidates, clients, and business partners, may use our reporting system to report or seek consultation if they become aware of any actions by our executives or employees that violate or may violate laws and regulations, or if they have experienced or become aware of harassment by our executives or employees.

The reporting system has two points of contact, one interna, managed by an in-house employee, and one external, managed by a legal firm.

Confidentiality and the protection of the privacy of those who report are strictly upheld, and retaliation or any unfavorable treatment against those who report are prohibited.

If, following an investigation, it is determined that there has been a legal violation, human rights violation, or an instance of harassment, disciplinary action and corrective measures will be taken, along with efforts to prevent recurrence.

Contact Points

When making a report, please be sure to review the Notes on Using the Incident Reporting System.

Reporting by e-mail

Reporting by written document (mail)

Incident Reporting Hotline, JAFCO Group Co., Ltd.
Toranomon Hills Mori Tower 24F 1-23-1 Toranomon, Minato-ku, Tokyo 105-6324

JAFCO Group Incident Reporting Hotline, Ayako Ito, Miyakezaka Sogo Law Offices
Hibiya Chunichi Building 6F 2-1-4 Uchisaiwaicho, Chiyoda-ku, Tokyo 100-0011

In response to the global trend in the establishment and strengthening of bribery prevention systems, we have established the Basic Policy on Bribery Prevention to address prevention of improper transactions. We ask our business partners for their understanding and cooperation.

Clarification of Responsibilities

We have established the necessary matters with regard to the handling of public research funds, etc. in accordance with the Guidelines for Managing and Auditing Public Research Funds at Research Institutions (implementation standards) to ensure their proper management and promote appropriate and smooth operation. With the President as the Chief Administrative Officer, the officer in charge is appointed as the Supervising Officer and the manager of the department handling competitive funds is appointed as the Compliance Promotion Officer.

Consultation and Contact Points

We have established the following contact points for consultation and reporting, aiming to further ensure the appropriate use of public research funds, etc. (Japanese only)