COMPANY INFO

Compliance Regulations

Article 1 (Purpose)
（１）Oscar Japan Inc. (hereinafter referred to as “the Company”) defines compliance of the Company as 　　　strict compliance with laws and regulations (including administrative notices, guidelines, etc.), internal 　　　rules and regulations, and responsible and sensible behavior based on social norms. The officers and 　　　employees of the Company shall perform their duties with compliance as the top priority management 　　　issue.
（２）These regulations stipulate the basic compliance rules and principles for the implementation and 　　　operation of compliance at the Company.

Article 2 (Scope of Application)
These rules shall apply to all officers and employees of the Company and its affiliates (including contract employees, part-time employees, seconded employees, temporary employees, retired employees, and other employees engaged in the Company’s business).

Article 3 (Compliance)
1. Maintenance of ethical standards and respect for human rights
（１）We shall be aware that we are members of the international community, maintain high ethical 　　　standards and employee ethics, and act honestly and fairly with a sense of decency and 　　　responsibility as members of society.
（２）Respect human rights and do not discriminate on the basis of race, culture, creed, gender, 　　　social status, religion, nationality, age, or mental or physical disability.

2. Compliance with laws and regulations, and prohibition of illegal acts and violations
（１）Always be aware of all laws, regulations, and social norms, and ensure compliance with them.
（２）We will not engage in any act that violates compliance, including any preliminary act.
（３）We will not instruct or suggest to other officers and employees any act that violates compliance.
（４）We will not tolerate any non-compliant behavior by other officers or employees.

3. Work Environment
（１）We will respect each other, freely exchange opinions, and create an open and cheerful work 　　　environment so that executives and employees can fully demonstrate their abilities.
（２）We will not disrupt the healthy public morals, environment, or order in the workplace through 　　　sexual harassment, power harassment, or any other conduct that offends public order and morals.

4. Conflicts of Interest and Distinction between Public and Private Mattersz
（１）We will not engage in any conduct that harms the interests of the company for the benefit of ourselves 　　　or a third party.
（２）Do not misuse company assets or confidential or personal information.
（３）Do not engage in other occupations without the Company’s consent.
（４）Do not acquire shares in a non-public company’s business partners or investees without the 　　　Company’s approval.
（５）Make a clear distinction between public and private matters and work transparently.

5. gifts and entertainment
（１）We do not give money, gifts, entertainment, or other economic benefits to public officials or similar 　　　persons in connection with their duties.
（２）We do not give or receive money, gifts, entertainment, or other economic benefits that deviate from 　　　social common sense or socially accepted norms to or from our business partners or other executives 　　　and employees.

6. handling of information
（１）Company confidential information and customer information shall be strictly controlled and shall not 　　　be divulged to any third party.
（２）Personal information shall be thoroughly protected and shall not be leaked or used for any other 　　　purpose.
（３）Confidential information disclosed by third parties shall be handled in the same manner as company 　　　information.
（４）We do not infringe on the intellectual property rights of others, such as unauthorized copying of 　　　computer software.
（５）We do not engage in unfair competition, such as the unauthorized acquisition or use of other people’s 　　　trade secrets. 7.

7. social contribution and environmental preservation
（１）We will strive to harmonize with local and international communities, build friendly relationships with 　　　stakeholders, and actively contribute to society in order to realize affluent and better local and 　　　international communities.
（２）We shall comply with laws and regulations concerning environmental preservation, and actively 　　　engage in educational activities related to environmental preservation.
（３）We shall not provide money, gifts, entertainment, or other economic benefits to public officials or 　　　similar persons in connection with their duties. 8.

8. response to anti-social forces
（１）If we receive any unreasonable demands from antisocial forces, such as general assembly members, 　　　organized crime groups, etc., we shall take a resolute stance and sever all relationships with them 　　　without seeking easy monetary solutions.
（２）We shall not engage in any transactions with antisocial forces, their related parties, or business 　　　partners who are related to antisocial forces.

9.Reporting and Disciplinary Action
（１）When an officer or employee is in doubt as to whether or not his or her actions or decisions violate 　　　compliance, he or she should consult with a director or the general manager of the Administration 　　　Department.
（２）When an officer or employee discovers an act or a potential act of non-compliance, he/she shall 　　　report or consult with a director or the general manager of the Administration Department. If all 　　　directors or the general manager of the administrative department are concerned, they shall consult 　　　with legal counsel, etc.
（３）Officers and employees shall cooperate in fact-finding investigations regarding the existence of 　　　compliance violations. If the investigation reveals a violation, the violator and those responsible 　　　for supervising the violator may be subject to disciplinary action in accordance with employment 　　　regulations, etc.
（４）Management will take every precaution to ensure that officers and employees who report or 　　　cooperate with fact-finding investigations concerning noncompliance will not be treated unfavorably.

Article 4 (Disciplinary Action and Prosecution)
Any officer or employee who commits a compliance violation or who causes a compliance violation by failing to fulfill his or her responsibilities under this Code shall be subject to disciplinary action in accordance with the Employment Regulations. In addition, any person who commits an act that constitutes a serious violation of penal laws and regulations shall be prosecuted by the authorities.

Article 5 (Doubts on Interpretation)
In case of doubt regarding the interpretation of these regulations, the General Manager shall decide after consultation with the heads of the departments concerned.

Article 6 (Supplementary Provisions)
The enactment, amendment, or abolition of these regulations shall be made by the decision of the President and Representative Director.

Article 7 (Enforcement)
These regulations shall go into effect on January 6, 2024.