Compliance

Basic Philosophy

"We ensure a sustainable future by creating a cohesive society with customers and partners" is one of Values of the Socionext Group. To achieve this, it is essential to promote fair business and transactions, and the Group has established the CSR Policy as its basic philosophy. Based on this CSR Policy, the Group has established the Compliance Code as part of our Group regulations and ensures that all Group employees act with a high sense of ethics and compliance awareness. We also conduct annual internal audits to confirm that business operations are being conducted in accordance with our basic policies, various regulations and guidelines. Furthermore, violations of these codes and regulations are subject to disciplinary action in accordance with internal regulations.

[Items and concepts specified in the Compliance Standards]

●Compliance with laws, regulations and social standards

We fully comply with laws, regulations and social standards, thus earning the trust of society. We will comply with the laws and regulations of the countries and regions where we conduct business activities and will not engage in illegal activities such as scams, fraud and money laundering. In addition, we monitor the status of enactment and revision of laws and regulations in each country where we conduct business activities, prepare internal regulations in a timely manner, and disseminate them through e-learning and other means.

●Respect for human rights

We respect each individuals's rights and do not discriminate or tolerate human rights violations. We respect the human rights of all stakeholders (Customers, business partners, employees, local communities, etc.) involved in our business activities, and do not violate human rights or engage in discriminatory treatment based on gender, age, nationality, race, ethnicity, ideology, religion, social status, employment status, marital status, pregnancy status, family origin, sexual orientation or gender identity, physical characteristics, disease, or disability. We have established Group regulations to prevent discriminatory treatment of employees and candidates for employment. Any violation of the regulations is subject to disciplinary action in the work rules. We also present our business partners with CSR Procurement Guidelines established by our company and urge them to respect human rights and to prohibit human rights violations.

●Establishing an improved work environment

We want our employees to be happy. We respect individuality, treat them fairly and aim to create a healthy and comfortable work environment. We maintain a safe and healthy working environment by complying with laws and regulations related to labor and health and safety.

●Environmental consideration

We conduct our business with consideration for global environment. We comply with the environmental laws and regulations of each country in which we operate our business and strive to develop products that contribute to reducing environmental impact.

●Promoting fair trade

Our relationship with our customers and business partners are built on trust, in accordance with practice fair trade. We will comply with the competition laws, anti-bribery and anti-corruption laws of each country and will not engage in activities that raise suspicion.

●Information management

We carefully manage and ensure the confidentiality of company information, third party information from our customers and business partners, and personal information. We have established a system for managing confidential information and require all officers and employees to comply with it.

●Respect for intellectual property

We value and protect intellectual property, which is the primary corporate asset. Our company has established a system for the creation, protection and exploitation of its intellectual property, and is fully aware of and thorough in ensuring that intellectual property of other companies is not misused.

●Handling of Antisocial Forces

Socionext will never have any relationship with antisocial forces, and will never carry out any activities that promote antisocial forces.

Compliance Administration

●Risk and Compliance Committee

Our group has a Risk and Compliance Committee made up of executives and others and led by the CEO. The committee meets once a quarter to assess, analyze, and formulate actions on issues such as compliance, information security, and disaster risks. In the event of an incident, we will appoint a responsible person and take prompt action. We will also analyze the cause of the incident and formulate and implement measures to prevent recurrence.

●Internal Reporting System

Our group has established an internal reporting (Whistle-Blowing) system for the early detection and response to unauthorized activities that is intended to reinforce fair business practices that are in accord with the law. The system provides for both internal reporting (to the Socionext Risk Compliance Committee Secretariat/Full-time Audit & Supervisory Committee Member) and external reporting (to the Socionext Reporting Contact at TMI Associates). The diagram below shows a flowchart of how this works.

In accordance with the law and company policy on this issue, measures are in place to ensure that the persons making and receiving reports are not identified so as to prevent them from being subject to any unfavorable treatment. To date, the company has not received any reports of serious breaches of the law, CSR policies, or company rules.

[Internal reporting flowchart]

Internal reporting flowchart

Main Actions on Compliance

●Promotion of Fair business transactions

In order to promote fair business transactions and anti-corruption measures, the Socionext Group has established the following Group Policy and is working on measures to ensure thorough dissemination. Since its inception, Socionext group has not violated any national competition, antitrust or anti-corruption laws.

(1)We conduct business transactions by fair means based on the principle of free competition and in compliance with national competition laws.

(2)We do not participate in agreements with competitors that may violate national antitrust laws and do not engage in practices that raise such suspicions.

(3)We comply with national anti-bribery and anti-corruption laws and do not engage in acts that invite such suspicion.

(4)We will comply with Political Funds Control Act and other related laws and regulations regarding political contributions and social contributions. In addition, we will conduct activities in a transparent manner that is consistent with our Group's basic philosophy and policies and that emphasizes the public interest of contributing to society as a whole.

[Main measures]

We are working to prevent corruption by thoroughly disseminating rules prohibiting entertaining and giving gifts to public and foreign officials, applying in advance for entertaining and giving gifts, and conducting regular surveys on entertaining and receiving gifts.

All employees receive e-learning education, which includes explanations of relevant laws and regulations (Antimonopoly Law, Unfair Competition Law, etc.) and examples of violations, to continuously raise employee awareness.

Related Party Transaction Management Rules. The Company examines the reasonableness of transactions and the appropriateness of terms and conditions and eliminates inappropriate transactions such as conflicts of interest.

Our group has no record of political donations or contributions to outside organizations.

●Compliance education and Training

Our group conducts education and training to raise employee awareness and understanding of compliance.

The main instances of compliance education and training in the fiscal year ended March 31, 2025 were as follows.

[Education and training]

Basic compliance education for all employees provided by e-learning (100% participation)

e-learning programs for all employees on the following topics (100% participation)
Laws on subcontractor payments and security-related export controls, harassment prevention, information security, anti-bribery & corruption and insider trading prevention.

Group classes for new recruits on compliance, information security, and human rights

●Ensuring exclusion of Antisocial forces (organized crime)

The Socionext Group stipulates the exclusion of antisocial forces in its CSR policies and compliance criteria, explicitly declaring its intention to be resolute in its attitudes and response to all forms of antisocial activity and to avoiding such relationships, with this stance being clearly communicated to employees. The company has also formulated rules on dealing with antisocial forces and laid out specific measures for their exclusion.

[Key measures]

To ensure the exclusion of antisocial forces, provisions to this end are either included in supplier and other contracts or are contained in separate agreements reached with such parties.

We cooperate with the Police and has put measures in place to collect information about antisocial forces. It has appointed a person to be responsible for preventing extortion and has joined an association of companies in Kanagawa for defending against such forces.

External agencies or similar are used to review all parties with which we have contractual arrangements to determine whether they have connections with antisocial forces or are suspected of doing so, both at the time of entering into the contract and at regular intervals thereafter.

●Action on Preventing Insider trading

Socionext has formulated rules for preventing insider trading, with stipulations that include the appropriate handling of material information and the pre-approval and post-fact reporting of company shares. We also ensure that these rules are clearly communicated to employees. To ensure that insider trading does not occur, the rules have also been accompanied by an e-learning course for all employees to raise their awareness and understanding of the topic.

[Management of insider information]

In accordance with laws, regulations, and internal regulations, we will appropriately manage insider information.

In order to prevent the leakage of financial information and ensure fairness, the period from the day after the end of the fiscal year (quarterly settlement) to the date of the announcement of financial results is designated as a "quiet period," and during this period, in principle, we refrain from answering comments or questions related to financial results. However, even during this period, timely disclosure may be made in accordance with the Timely Disclosure Rules.