1. Prohibition of Bribery and Corruption

Sun Frontier Group prohibits any acts of bribery or corruption, whether direct or indirect, involving the exchange, offer, or promise of money or any tangible or intangible benefits to Public Officials and individuals in equivalent positions within or outside Japan, for the purpose of gaining unfair business advantages.

This includes facilitation payments (small unofficial payments to expedite routine government actions).

Additionally, entertainment and gifts in relationships with business partners and related parties shall be conducted within the bounds of social norms and in compliance with the laws of each country.

2. Compliance with Applicable Laws and Regulations

Sun Frontier Group conducts its business activities in compliance with applicable laws and regulations in each country to ensure that no acts of bribery or corruption are committed against Public Officials.

3. Education and Awareness

Sun Frontier Group provides education and training to its Officers and Employees to ensure the proper implementation of these guidelines in all business activities.

4. Record-Keeping and Financial Controls

Sun Frontier Group ensures that all instances of providing entertainment, gifts, or other economic benefits to Public Officials by its Officers and Employees are appropriately recorded in compliance with applicable laws and internal regulations.

5. Reporting Obligations

Sun Frontier Group has established an Ethics and Compliance Helpline to prevent and promptly detect misconduct, enhance the effectiveness of internal controls, manage reputational risks, and ensure public trust.

These guidelines stipulate the obligation and procedures for reporting any known or suspected violations by Officers and Employees.

The system also allows for anonymous consultations and communications and prohibits any retaliatory or disadvantageous treatment for using the helpline.

6. Disciplinary Actions and Corrective Measures for Violations

Sun Frontier Group will take strict disciplinary actions and corrective measures based on internal regulations against any Officers and Employees who violate applicable laws or these guidelines.

7. Revisions

Sun Frontier Group will promptly revise these guidelines as necessary to comply with applicable laws and regulations.

Established on: March 18, 2025