DHC Group Code of Conduct

Basic principles

The DHC Group Code of Conduct (hereinafter referred to as the gCodeh) serves as the framework for the rules, regulations, and provisions with which all officers and employees of DHC Corporation and its subsidiaries (hereinafter referred to collectively as the gDHC Grouph) are required to comply in carrying out their duties. Should matters not specifically addressed in this Code arise, as is likely in todayfs rapidly changing business environment, officers and employees are obliged to act in accordance with the spirit of this Code.

This Code sets forth general guidelines for everyday business activities. Officers and supervisors shall, as necessary, incorporate more specific guidelines concerning the operations for which they are responsible into in-house rules, procedural manuals, and other documents, with the goal of incorporating the spirit of the Code into every aspect of our day-to-day business activities.

Code of Conduct

1. Compliance with laws, regulations, and other requirements

(i) As good corporate citizens, we will comply with laws and regulations and act with integrity in accordance with their spirit.
(ii) We shall fully comprehend and comply with the Companyfs rules and regulations.

2. Fair transactions

(i) We will refrain from any actions that lead to unfair competition, and from transactions counter to existing laws and regulations or that are not aligned with sound business practices.
(ii) We will refrain from using our status or authority to obtain or provide to others illicit gains or benefits through our business transactions.
(iii) We will not accept or provide gifts of money or entertainment to or from our counterparties beyond those in accordance with socially accepted norms.

3. Appropriate information control

(i) We will not disclose confidential information of the Company, our counterparties or other parties, or personal information of customers, employees, or other parties.
(ii) We will not engage in insider trading of stock or other securities based on confidential or non-public information of the Company, our counterparties, or other parties.
(iii) We will strive to provide the required information to shareholders in an appropriate and timely manner.

4. Environmental protection

(i) We will strive to minimize and process waste appropriately at all stages of Group business activities, including at headquarters and individual stores.
(ii) We will strive to protect the environment through effective use of resources.

5. Regard for ethical norms

(i) We will refrain from discrimination based on gender, birthplace, race, ethnicity, nationality, creed, religion, social status, or other personal attributes.
(ii) In our activities in Japan and around the world, we will strive to understand and respect the cultures and practices of each country and region, and act at all times in a spirit of gratitude to local communities.
(iii) We will take a firm stand against antisocial forces, and will have no relations with or provide any aid or benefits thereto.

6. Reliable financial reporting

(i) We will emphasize clear and accurate financial reporting.
(ii) We will ensure reliable financial figures through fair and proper processing at all stages, from procurement through sales.
(iii) We will seek to recognize all risks related to financial reporting and take appropriate measures therefor in response.
(iv) We will strive to improve the reliability of financial reporting through monitoring and audits.

Basic policy on reliability assurance

To provide products that satisfy our customers as well as earn their trust, stepping beyond compliance with all statutory laws and regulations, we devote extensive efforts to assure reliability at all stages of the product journey, from planning and development through production, sales, and post-sales.