1. Prohibition of Bribery and Corruption

Sun Frontier Group prohibits the direct or indirect giving, receiving, offering, or promising of money or any other tangible or intangible benefits to or from public officials in Japan or abroad, or those in equivalent positions (hereinafter referred to as "Public Officials, etc."), for the purpose of obtaining illicit business advantages. This includes small payments made solely to facilitate administrative services (facilitation payments). Furthermore, entertainment and gifts in relations with business partners and related parties shall be conducted within a socially acceptable range in compliance with the laws of each country.

2. Compliance with Relevant Laws and Regulations

The Sun Frontier Group conducts its business activities in compliance with the relevant laws and regulations of each country (hereinafter referred to as "Relevant Laws") to ensure that no acts of bribery are committed against Public Officials, etc.

3. Education and Awareness

The Sun Frontier Group will ensure that all officers and employees of the Group (hereinafter referred to as "Officers and Employees") are fully aware of these guidelines through education and training and will raise awareness regarding initiatives to prevent international bribery and other corrupt practices.

4. Management of Payment Records

The Sun Frontier Group will comply with Relevant Laws and internal regulations when Officers and Employees provide entertainment, gifts, or other economic benefits to Public Officials, etc., and will appropriately record all such instances.

5. Obligation to Report

The Sun Frontier Group has established a "Corporate Ethics Helpline" to prevent and early detect scandals caused by legal violations or improper conduct, to improve the agility of self-purification processes, to control reputation risks, and to ensure social trust. We have established reporting obligations and procedures for cases where an Officer or Employee becomes aware of such acts or suspected acts. We also accept anonymous consultations and communications and prohibit any disadvantageous treatment of individuals for using this system.

6. Measures for Violations

The Sun Frontier Group will take strict action, based on internal regulations, against any Officers and Employees who violate Relevant Laws or these guidelines.

7. Governance

Compliance activities, including the prevention of corrupt practices, are reported to the Board of Directors once a year, and the Board of Directors provides supervision.

7. Revision

The Sun Frontier Group will promptly revise these guidelines as necessary to ensure compliance with Relevant Laws.

Established on: March 18, 2025
Revised: March 1, 2026