Corporate Ethics Charter

• Established

• April 11, 2006 (Revised January 21, 2019)

• Significance and Purpose

• The Leopalace21 Group does business based on our corporate philosophy to "create new value". As part of that process, we have set out a Corporate Ethics Charter. We are determined to establish legal and social compliance as the cornerstone of all of our corporate activities. This is exemplified by our President and CEO, whose role is to continuously share the spirit of this charter with all group company officers and employees.

Establishing trust

Article 1

Officers and employees shall make every effort to establish public trust, by remaining aware of the Leopalace21 group's corporate mission and ensuring that operations are carried out in a responsible and sound manner.

Respect for the customer

Article 2

Officers and employees shall use their imagination and ingenuity to provide the highest quality products and services in line with customers' needs, through every aspect of the Leopalace21 group's operations.

Transparent and sound management

Article 3

Officers and employees shall maintain appropriate and harmonious relationships with customers, shareholders, investors and other stakeholders, make every effort to disclose management information fairly, adequately and in a timely manner, and ensure that management is transparent and sound.

Legal compliance

Article 4

Officers and employees shall rigorously comply with all applicable laws and regulations, and ensure that operations are carried out fairly. In the event of any doubts regarding the validity or legality of operations, they shall consult the relevant department.

Dealing with antisocial forces

Article 5

Officers and employees shall resolutely oppose all antisocial forces posing a threat to public order or safety.

Information management

Article 6

Officers and employees shall manage all information obtained during the course of their duties with meticulous care and attention, to ensure that no information is leaked or used for the benefit of any individual or third party.

Environmental initiatives

Article 7

Officers and employees shall take the environment into consideration when carrying out operations, and shall make every effort to work in harmony with society.

Respect for human rights

Article 8

Officers and employees shall respect all people and their rights, and shall not engage in any form of prejudice or discrimination.

Revision or abolishment

Article 9

The President and CEO shall authorize the revision or abolishment of this Charter.