The SG Holdings Group strives to create a corporate culture in which every employee conducts business with high ethical standards and compliance standards and responds appropriately to changes in the social and business environment. The SG Holdings Group Code of Ethics and Conduct constitutes the backbone of the Group’s compliance posture. Based on the Code of Ethics and Conduct and the Compliance Regulations, the Group has built and maintained a culture of conducting business with high ethical standards, continually striving to improve our business operations and our credibility with the public.

SG Holdings has built a compliance system while coordinating with Group companies centered on the departments responsible for legal affairs, and the Internal Audit Department performs checks on compliance.

Furthermore, we operate the SG Holdings Group Compliance Hotline as an internal whistleblowing system. This is a hotline for employees and their family members, along with partner companies to report any actions in violation of laws and regulation, internal rules or the Code of Ethics, and an external hotline and an overseas hotline have also been established.

Furthermore, the SG Holdings Group is actively engaged in the prevention of insider trading. We have established a system of controls including a blackout period and an advance application procedure for trading shares.

The SG Holdings Group periodically conducts education on the Code of Ethics and Conduct for all employees of the Group for the purpose of cultivation of employees' ethical standards and the self-cleansing effect based on that. We also conduct internal control seminars for executives and managers, provide education on the Subcontractors Act, and provide education tailored to each Group company. We provide information and raise awareness of all employees of the Group concerning compliance items with set themes through documents such as the Compliance Newsletter and the Internal Control Newsletter via the Group's internal portal website.

Harassment prevention training is implemented twice per year. We also provide separate manager training for managers.

For the purpose of eliminating dealings with criminal elements that threaten the safety and order of society, we have established Exclusion of Anti-social Forces Regulations. We are working hard to block relationships with anti-social forces, firmly refusing to respond to unjust demands, backroom deals, or provision of funds. This is clearly stated in the Basic Policy of Internal Control, the Charter of Corporate Conduct, and the Code of Ethics and Conduct, and we work to ensure that all employees are fully cognizant of them. More specifically, we have (1) instituted the continuous review ("anti-social check") of attributes of counterparties (both customers and business partners) and (2) established an Unjust Demand Hotline to ensure the quick resolution of cases when employees receive unjust demands. We continue to strengthen these systems and by sharing information on anti-social forces and responses to them we strive to fully prevent and block interference of our business partners.

In order to conduct its business in a sound manner, the SG Holdings Group takes measures to effectively manage its intellectual property and ensure knowledge and awareness of intellectual property.

We have established the Intellectual Property Deliberation Committee as a means of protecting the Group’s intellectual property, work to obtain legal proprietary rights over the intellectual property of each Group company based upon the full review and recommendations of that committee and centrally manage and maintain those rights.

In order not to infringe on the intellectual property rights of others, we constantly monitor the intellectual property rights where there is the possibility of infringement by us and disseminate information to the concerned units to ensure that they take appropriate precautions. We continually make efforts to promote knowledge and awareness about these activities throughout the Group.