Group CSR Charter, Group Code of Conduct

Group Code of Conduct

To implement the Corporate Social Responsibility (“CSR”) Charter and carry out its spirit, we have established the Sega Sammy Group Code of Conduct (the “Group Code of Conduct”), applicable to all respective stakeholders.

Introduction

This Group Code of Conduct, along with the SEGA SAMMY Group Management Policies and Guidelines, uniformly applies to the Sega Sammy Group, including subsidiaries and affiliates throughout the world as well as all of the officers and employees thereof (collectively the “Employees”).
The Group Code of Conduct also applies to the standards and policies in place in each subsidiary and affiliate.

However, while the Group Code of Conduct provides general guidelines, it is not meant to detail all specific policies.

Thus, Employees should continue to look to and follow the specific internal rules and regulations set up by their specific company.

Preamble and General Overview

"Sound Management"and "Fair and Open Corporate Activities"

1.We will always aim to implement sound management practices.

2.By using proper accounting methods, and conducting efficient assets management and appropriate profit distribution to shareholders, we will strive to improve the worth of the enterprise.

3.We will compete through fair and open corporate activities, and pursue profits.

4.Top management will recognize that its role is to implement the spirit of this Group Code of Conduct, and to strive to ensure all Employees are aware of and understand this Group Code of Conduct, while taking the initiative in serving as role models.

5.If any corporate activity occurs that conflicts with this Group Code of Conduct, top management will take the initiative in: improving the processes related to the event; settling the problem; striving to investigate the cause and prevent any recurrence; assuring accountability by actively disclosing information on any countermeasures employed; and properly punishing any violator (including members of senior management) in accordance with any applicable rules such as internal regulations.

"Compliance with Laws and the Social Code" and "International Development"

6.We will always comply with the applicable laws of the countries or territories where we have our business; and will not commit any illegal acts.

7.We will execute our operations, by striving to understand and properly work within, at the highest level, the social code, social norms and common sense of the countries or territories where we have our business.

8.We will establish specific management systems and take appropriate export procedures with regard to the export of technology and goods that are subject to regulation under relevant laws and regulations. (Note 1)

9.We will comply with all applicable internal rules including company regulations.

"Prohibition of Offering of Bribes"

10.We will not carry out any acts that may be construed as the offering of bribes, favors or gifts to people who are prohibited from receiving such bribes, favors or gifts by relevant laws, both at home and abroad (Note 2), such as politicians, civil servants (including deemed civil servants who are officers or employees of corporations or associations) and foreign civil servants.

"Respect for Intellectual Property Rights"

11.We will comply with relevant laws and regulations concerning patent rights, copyrights, etc., (Note 3) and will respect legitimate intellectual property rights of third parties and will not intentionally infringe upon or engage in any unauthorized use of the same.

""CSR" and "Dialogue with Our Stakeholders""

12.We will understand the mission of the Sega Sammy Group, and do our best in our individual capacity, in order to achieve Sega Sammy Group’s goals.

13.We will strive to understand the Sega Sammy Group CSR Charter and develop a good relationship with our stakeholders.

"Self-Assessment and Reporting"

14.In the performance of our operations, we will ensure our actions do not conflict with relevant laws or company regulations.

15.If there is any violation or possible violation of relevant laws or company regulations, we will properly investigate the matter, improve our procedures to prevent any recurrence, and try to remain a sound enterprise.

16.In any opportunity of our communication(including the case of communication made through mass media or social media, etc.), we understand our social responsibility for our words and deeds and will strive to engage with care.

"Respect for Human Rights" and "Elimination of Anti-Social Forces"

17.We will recognize that all human beings have equal human rights, and we will respect those rights.

18.We will strive to protect human rights and not to commit any acts that abuse those rights.

19.We will resolutely handle any undue demands arising from an organized crime group, an organized crime group member or any other anti-social forces; and not only will we not offer any payoffs but we will also eliminate any relationships therewith.(Note 4)

Relations with Customers

"Security, Safety and High Quality," "Customer Satisfaction" and “Ensuring the Safety of Products"

1.We will strive to provide secure, safe and high-quality products and services that always meet our customer’s expectations.

2.We will strive to always listen to our customer’s opinions, and provide products and services that are satisfactory to our customer.

3.We will strive to always look at our operations from our customer’s perspective, and provide products and services at an appropriate price and in a prompt manner.

4.We will strive to continually monitor the market, be sensitive to changing trends, improve technology and create new ideas.

5.When we perform product design at our own responsibility, we will strive to ensure that products meet the safety standards as set forth in the relevant laws and regulations, etc., of each country.

"Proper Business Relationships" "Information Disclosure" and "Claims and Reporting"

6.We will always maintain proper business relationships with our customers. We will not conduct any activities such as: unduly low bargain sales that might damage profits; or acts that are not considered to be normal commercial activities.

7.We will actively disclose information to our customers that is useful for their further understanding of the corporate activities, products and services of the Sega Sammy Group.

8.We will carefully examine and take appropriate measures to handle claims against the company, accidents or any other problems.

Relations with Partners

"Fair Business Relations" and "Impartial Selections"

1.Our relationships with trade partners will always be conducted cleanly, transparently and fairly; and we will not engage in any acts that might be misinterpreted as being part of a “cozy relationship” or collusion.

2.In our relationships with trade partners, we will not engage in any transaction that causes undue detriment by abusing our dominant bargaining position over them (Note 5).

3.As to the selection of trade partners, we will comprehensively consider such characteristics as creditworthiness, technological capability, development capability, price, adaptability to environment, and judge them based on fair and open standards.

4.We will conduct transparent and fair transactions even within our group companies.

"Entertainment and Gift-Giving"

5.When entertaining or giving gifts to trade partners, we will not only follow internal rules stipulated by the relevant company, but will also, in view of social common sense, remain moderate in our conduct and make appropriate judgments.

"Individual profits"

6.We will not pursue personal profits from trade partners including receiving profits or favors by using our individual positions.

Relations with Shareholders and Investors

"Highly Transparent Management" and "Interactive Communication"

1.We will comply with relevant laws and other rules; properly and fairly disclose company information; and strive to secure transparency in management.

2.We will actively listen to the voices of shareholders, and strive to achieve bilateral and interactive communication.

"Positive and Fair Disclosure Attitude"

3.We will strive to pro-actively disclose company information that contributes to helping investors understand our group.

4.We will strive to treat all investors equally and to prevent company information being unevenly distributed.

"Proper Return of Profits", "Maximization of Enterprise Value" and "Perpetuity"

5.We will efficiently manage assets and properly return profits to shareholders.

6.By always keeping an eye on global situations and trends and responding to social needs, we aim to maximize enterprise value and grow continuously.

"Insider Trading"

7.We will comply with the laws, company regulations and rules regarding insider trading (Note 6), and handle undisclosed material facts in strict confidence.

Relations with Employees

"Improvement of Workplace Environment"

1.By considering the safety and health of employees, we will build a workplace environment where employees can work with a sense of security.

2.We will create a company, which enables employees to fully utilize their individual capabilities and to feel “rewarded” and “challenged”

"Harassment" and "Discrimination"

3.We will not commit and will prevent any acts that disturb the workplace environment such as sexual harassment, harassment by superiors and invasion of privacy.

4.We will not commit and will prevent both discriminatory acts that damage equal employment opportunity and discriminatory treatment based on such factors as a person’s race, beliefs, sex, age, disability, academic background or family origin.

Relations with Society

"Prosperity in Core Business"

1.We will always aim for our core business to prosper by providing products and services satisfactory to our customers, and will not forget to contribute to society by paying taxes and creating employment.

"Contribution to Society" and "Donations"

2.Not only will we contribute to society through our business activities, but we will also actively and voluntarily support cultural interests such as the arts and sports to contribute to the realization of a prosperous society.

3.In engaging in the above socially contributing activities (including giving donations), we will comply with any internal rules stipulated in accordance with related laws including tax laws, the Commercial Code of Japan and the Political Funding Regulation Law.

"Local Community"

4.As a locally-rooted company, we will actively and voluntarily strive to promote solidarity and cooperation with, and engage in exchange with, the local community.

"Global Environment"

5.We will consider the possible effects on the global environment stemming from all elements of our products overall lifecycles, ranging from material procurement, manufacturing, distribution, use, recycling and disposal.

6.To protect the global environment, we will not only comply with related laws and various regulations, but will also actively and voluntarily consider and implement any further measures we believe will benefit the global environment.

7.We will nurture our personnel, to be highly aware of the global environment and to strive for material and energy conservation, both personally and professionally.

Supplementary Notes

(Note 1) Meaning the Foreign Exchange and Foreign Trade Act (Foreign Exchange Act), the Export Trade Control Order (Export Order), the Foreign Exchange Order, the Ordinance of the Ministry Specifying Goods and Technologies and the International Agreement on Security Export Control, etc.

(Note 2) Meaning the Unfair Competition Prevention Act, the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA), etc.

(Note 3) Meaning intellectual property rights, patent rights, utility model rights, design rights, trademark rights, copyrights, trade secrets, etc.

(Note 4) Meaning the Act on Prevention of Unjust Acts by Organized Crime Group Members (Anti-Organized Crime Group Members Act) and the Ordinance for the Elimination of Organized Crime Groups, etc.

(Note 5) Meaning the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade (Antitrust Act) and the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, etc.

(Note 6) Meaning Article 166 of the Financial Instruments and Exchange Act, etc.

UK Modern Slavery Act statement

In accordance with Article 54 of the UK Modern Slavery Act of 2015, SEGA SAMMMY HOLDINGS INC. hereby releases this statement on efforts to prevent slavery, human trafficking and other human rights violations in the businesses and supply chains of the SEGA SAMMY Group.

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