Code of Conduct

Management Policy

Group Management Policy

As part of the fundamental development of our group-wide compliance system, we, the SEGA SAMMY Group, have established this “SEGA SAMMY Group Management Policy,” which provides more detailed descriptions of the SEGA SAMMY Group Code of Conduct and specifies the minimum matters to be observed.
The applicable scope of this policy is the same as that of the SEGA SAMMY Group Code of Conduct.

The SEGA SAMMY Group will establish internal rules and other regulations that exceed the standards specified in this policy, or make arrangement to apply this policy after having made changes as appropriate, and promote the execution thereof.

SEGA SAMMY Group Human Resources Policy

Basic Concept

We, the SEGA SAMMY Group, consider that the creativity and adventurous spirit of each of our respective employee are the source of our development and that “employees are our most important assets (human resources).” We aim to realize the arrangement of an environment in which employees can enhance their own value and work energetically with a sense of pride and satisfaction.

Basic Policy

(Realization of a Harmonious Working Environment)

We respect individuality and will promote the realization of a culture in which each employee thinks for himself/herself and demonstrates his/her ability and creativity, thereby enabling each employee to reach his/her full potential.
We offer a flexible work style which provides an appropriate work-life balance, taking into consideration the balance between each individual’s life and work, and, at the same time, promote the realization of a vibrant corporate culture such as through our promotion of diversity.
We do not allow discrimination (Note 1) in job offering/employment and strive to realize equal opportunities and fair treatment for all.

(Labor Management)

We will comply with all applicable labor related laws concerning minimum wages, overtime work, statutory benefits, working hours, etc., and reward our employees with appropriate remuneration upon conducting fair evaluations.

(Workplace Safety)

We provide a work environment in which employees can work safely and harmoniously.
We respect our employees’ human rights and prohibit any severe and inhumane treatment such as abuse, physical punishment, sexual harassment and power harassment (i.e. harassment by way of verbal abuse or coercive acts).

(Others)

We respect our employees’ right to organize for labor-management consultation.
We employ all of our employees at their own free will and do not impose any forced labor on any employee by way of assault, intimidation, confinement or other measures under which mental or physical freedom is unfairly restricted, etc.
We do not employ any child under the minimum working age. Furthermore, we do not cause any child to work and thereby hinder his/her development.

(Note 1) Discrimination means allowing different opportunities and/or treatment with regard to recruitment, promotion, remuneration, training, enrollment in training sessions, etc., due to any factor other than reasonable factors such as an employee’s abilities, aptitude and performance. The factors for discrimination include, without limitation, race, creed, gender, age, social status, family origin, nationality, ethnicity, religion, regional origin, skin color and sexual orientation.

SEGA SAMMY Group Occupational Health and Safety Policy

Basic Concept

Based on the concept that “the protection of health and safety is our utmost priority,” we, the SEGA SAMMY Group, act in compliance with relevant laws and regulations as well as with the voluntary management standards of each company and make efforts, as a group, to create a secure, healthy and safe work environment which is prepared to deal with potential accidents/disasters.

Basic Policy

(Health and Safety)

We will evaluate the risks concerning workplace security and ensure safety with appropriate designs and technology/management tools.
We will take appropriate security measures for any machinery and equipment, etc., that we use.
We will recognize the situations where any employee may come into contact with any chemical substance, noise or offensive odor that is harmful to the human body and take appropriate measures in response thereto.
We will recognize the situations surrounding industrial accidents and work-related illnesses and take appropriate measures in response thereto.
We will implement appropriate health management for all employees.
We will appropriately ensure the health and safety situation of the facilities provided for the benefit of employees (e.g., the cafeteria and restrooms).

(Disaster Prevention)

We will hypothesize which accidents, disasters, etc., may arise, prepare countermeasures in the case of an emergency and keep everyone in the workplace informed of the same in order to protect the safety of life and limb.
We will identify work that causes a heavy burden on the body and appropriately manage such work so as to prevent disaster/illness.

SEGA SAMMY Group Risk Management Policy

Basic Concept

The business environment surrounding us, the SEGA SAMMY Group, is rapidly changing and the risks associated therewith are complicated and wide-ranging. We consider that it is imperative for the continuation of our business that we not only respond to crises (emergency situations), but also that we grasp potential significant risks both within and outside of our operations.
In times of peace we will consider measures to prepare against potential material risks that may prevent us from maintaining or improving the promotion of our business and corporate values and we will construct systems that minimize potential losses, thereby putting forward our best efforts to minimize any effects on the various stakeholders involved and aiming to become a company that gains a strong level of trust from society.

Basic Policy

Through the practice of risk management, we will promote the continuous and stable development of our business and seek to safeguard our corporate assets.
We will place the utmost priority on the safety of human lives at times of emergency, and, in accordance with the “SEGA SAMMY Group Crisis Management Guidelines,” will put forward our best efforts to achieve a prompt recovery and minimize any hindrance to our business activities.
We will promote the spreading of risk awareness and the fostering of risk sensitivity by way of awareness-building activities such as education and training and by sharing risk-related information.
We will strive to prevent the reoccurrence of any crisis.

SEGA SAMMY Group Information Management Policy

Basic Concept

We, the SEGA SAMMY Group, recognize that, in the current advanced-information age, appropriately managing trade secrets and other information (“Confidential Information”), will provide protection for our corporate assets and will lead to the strengthening of our business, while at the same time considering it to be the social responsibility of the company.

We will comply with relevant laws, regulations, and other norms concerning the management of Confidential Information and will appropriately manage/protect any information, including Confidential Information, received from customers and third parties.

We will keep each employee thoroughly informed of the following “information management” policy, as well as the separately stipulated “IT security” policy and “personal information protection” policy.

Basic Policy

We have established internal regulations, etc., and will strive to strictly comply with relevant laws and regulations, etc.
In addition, we will provide constant education concerning the management of Confidential Information and take strict measures against violators.
In order to prevent the loss, destruction, falsification, divulgence, etc., of information, we will strive to achieve appropriate information management, such as restriction of access to information/management of information, countermeasures against unauthorized access/computer viruses and having a clear desk policy in the office.
We will identify each and every item of Confidential Information according to the applicable area and characteristics thereof and strive to achieve appropriate handling of Confidential Information according to the level of confidentiality.
In addition, we will strive to grasp the management status of Confidential Information on a periodic basis and will take necessary measures if any problem arises, etc.
We clearly specify our confidentiality obligations in our Work Rules and various regulations and also clarify the confidentiality obligations which are to be assumed by our employees.

（1）Employees are required to strictly manage the company’s Confidential Information and will not disclose or divulge the same without taking the applicable procedures under our internal regulations, etc., not only during their time of employment but also after resignation.

（2）Employees will not wrongfully or unjustly use the company’s Confidential Information, not only during their time of employment but also after resignation.

（3）Employees will not use any Confidential Information concerning customers, suppliers, sales partners and other business partners, etc., that they come to know in the course of their duties for any purpose other than a legitimate purpose and will manage the same in accordance with our internal regulations, etc., so as to prevent the disclosure or divulgence thereof.

（4）Employees will not access or obtain any Confidential Information from customers, suppliers, sales partners, other business partners and/or competitors by way of wrongful means.
If, by any chance, any divulgence of Confidential Information, etc., or any security-related problem occurs, we will investigate the cause thereof and take appropriate measures, such as promptly contacting related divisions or disclosing necessary information, etc., and will also strive to prevent the reoccurrence of the same at any time thereafter.

SEGA SAMMY Group IT Security Policy

Basic Concept

Given the fact that the rapid progress of the information age, such as through highly-networked information technology (IT), is currently having an increasing influence on corporate value, we, the SEGA SAMMY Group, consider that securing IT security and protecting information assets from various threats are important business challenges and that they also comprise the social responsibility of the company.

We will constantly practice the countermeasures based on this policy, improve the level thereof and aim to become a company that is always trusted by customers and other various stakeholders.

Basic Policy

(Compliance with Laws and Regulations)

We will comply with relevant laws, regulations and other social norms concerning IT security.

(Establishment of Systems)

Based on this IT security policy, we will determine the roles of persons in accordance with the duties they are engaged in and establish a system through which IT security can be promoted on a company-wide basis.
We will establish and implement management standards that stipulate the specific acts to be observed and evaluation standards thereof based on fundamental provisions that stipulate the basic IT security requirements in accordance with this policy.
We will implement appropriate human resource, physical and technical measures and strive to prevent the occurrence of any unauthorized intrusion, divulgence, falsification, loss, theft, destruction, or obstruction of usage, etc., in respect of information assets.
The management personnel who administer IT security will secure human resources who possess the necessary abilities to secure/maintain IT security and appropriately deploy such human resources.
The management personnel who administer IT security will (i) understand the separately stipulated “Basic Guidelines on IT Security” “Cloud Service Use Guidelines” or the guidance procedures, etc., set forth by each company, (ii) grasp the IT security situation, (iii) report the IT security conditions to the board of directors, etc., on a periodic basis, and (iv) strive to improve the same.
In order to secure stable IT operations, we will strive, even during normal times, to reduce risks and prevent any potential crisis.

(Response at the Time of Accidents)

If, by any chance, any security-related problem occurs or is likely to occur with regard to any information assets, we will promptly investigate the cause thereof and make efforts to minimize any damage caused thereby.

(Education)

We will provide education necessary for the securing/maintaining of IT security.

(Enhancement of Outsourcing Companies’ Management System)

Upon the execution of any service agreement, we will require the outsourcing company to maintain security levels that are equivalent or superior to those of our group and will thoroughly examine the eligibility of the same. In addition, we will confirm on a periodic basis whether these security levels are being appropriately maintained.

(Others)

If any employee breaches this IT security policy through his/her willful misconduct or gross negligence, such employee will be subject to punishment, etc., in accordance with the Work Rules.”

SEGA SAMMY Group Personal Information Protection Policy

Basic Concept

We, the SEGA SAMMY Group, fully recognize the importance of the personal information of our customers, business partners and employees (including contract employees, temporary workers, etc.) that we use in our business operations and consider that it is our social responsibility to appropriately conduct safe and secure management of such personal information.

We will conduct appropriate management of personal information (i.e. in the acquisition, use and provision thereof) in accordance with internal regulations, etc., and, at the same time, take necessary and appropriate security measures and strive to prevent the divulgence of information, etc.

Basic Policy

With regard to the handling of personal information, we will comply with the Act on the Protection of Personal Information and other norms.
We will provide appropriate explanations on our purpose of using personal information to the owner of such personal information (who is the subject of the same) and will only use such personal information to the extent that his/her consent is obtained and within the scope of such purpose of use. In addition, we will not provide or disclose any personal information held by us to any third party without the consent of the owner of such personal information except in cases pursuant to relevant laws and regulations, etc.
If an owner of any of the personal information held by us requests the disclosure, correction, deletion, etc., of his/her personal information, we will respond appropriately thereto in accordance with relevant laws and regulations.
We will make efforts to maintain the personal information held by us in an accurate and up-to-date content and, at the same time, make efforts to achieve the security necessary to prevent potential accidents such as unauthorized access or divulgence of personal information. In addition, if we outsource the handling of personal information to an outside company, we will take necessary measures to ensure that the outsourcing company manages personal information at a level at least equivalent to that performed by us.
We will constantly provide employees with education/training concerning the handling of personal information.
If, by any chance, an accident such as the loss/divulgence of personal information occurs in relation to the handling of personal information, we will promptly implement appropriate measures, including conducting an immediate investigation into the cause thereof and implementing countermeasures in order to prevent the reoccurrence thereof.
We will review our handling of personal information on a periodic basis and strive to achieve the continuous improvement thereof.

SEGA SAMMY Group IR/Public Relations Policy

Basic Concept

In our business activities, we, the SEGA SAMMY Group, will disclose our corporate information, such as that regarding our company’s management content and business activity situation, pursuant to relevant laws and regulations, and at the same time, we will transmit information, from time to time, through fair and appropriate methods.

Basic Policy

(Information Disclosure)

We will strive to achieve timely and appropriate disclosure of corporate information, such as management policies and financial data, so as to allow shareholders, investors and the local community, etc., to obtain an accurate understanding and thereby obtain their trust.
We will disclose our corporate information in a fair and appropriate manner in accordance with relevant laws, regulations and other rules and strive to ensure transparency in management.
We will strive to proactively disclose our corporate information that will help to contribute to investors’ understanding. In addition, we will contact all investors in a fair manner and strive to prevent the unfair distribution of our corporate information.
We will comply with relevant laws, regulations, internal regulations and rules concerning insider trading and strictly handle any non-public material facts.

(Public Relations)

We will engage in public relations activities in a sincere manner, based on objective facts.
We will not emphasize our superiority by way of unfairly criticizing any other company or by using any undignified expression. In addition, we will not deal with any political, religious or similar issue in the expressions used in our advertising, etc., and will not use any expression that evokes an image of racial discrimination or discrimination against those with mental or physical disabilities, etc., or any expression that may impair the dignity of our fellow human beings.

SEGA SAMMY Group CSR & SDGs Policy

Basic Concept

(Our future vision through CSR and SDGs)

The Sega Sammy Group believes that it is important to create an environment in which each and every employee takes pride in his/her work and will come to realize that they contribute to the sustainable development of society, by way of continuously providing “moving experiences” to people all around the world. By promoting CSR (Corporate Social Responsibility) and SDGs (Sustainable Development Goals), we aim to become a corporate group that is trusted, needed and respected by society.

Basic Policy

(Setting priority themes to be addressed)

By connecting our CSR activities with SDGs, we set the priority themes to be addressed and use them to promote our CSR and SDGs activities.
While ensuring cooperation with multiple stakeholders and promoting cooperation with them in each of our activities, we periodically confirm the important issues that should be addressed by the group as a whole.

(Release of information to the public and promotion of awareness within the group)

We establish policies on the promotion of CSR and SDGs and release them to the public on our website and through other media. In addition, we endeavor to promote awareness and understanding about our policies and the outline of our activities among the officers and employees of our group through training sessions, distribution of communication reports and other means.
We proactively release the results of our annual CSR and SDGs activities to the public through integrated reports, CSR booklets, our website and other media.

(Raising awareness of CSR and SDGs activities across the entire group)

While stipulating the policies for the entire group and engaging in activities in relation to CSR and SDGs, we require each of our group companies to establish plans for CSR and SDGs activities, receive reports on their performance and implement a PDCA (Plan-Do-Check-Act) cycle which evaluates the same, and we thereby develop such activities in a manner which relates to the entire group’s and each group company’s business activities.
We have established an organization that promotes CSR and SDGs activities, and it makes periodic reports to the Sega Sammy Holdings INC. Board of Executive Vice Presidents on the progress status of the group activities, thereby leading to the development of further activities.

SEGA SAMMY Group Environmental Policy

Basic Concept

Global environmental problems such as global warming, depletion of natural resources and waste pollution are becoming increasingly serious and the response toward environmental challenges is a top priority challenge that should be addressed by all corporations and individuals.

With the aim of achieving the “sustainable development of society,” we, the SEGA SAMMY Group, not only comply with the laws, regulations and rules concerning the environment, but also accumulate activities that exert a positive impact on the environment through such means as striving to conduct business activities in harmony with the environment, such as engaging in energy saving measures, recycling and reduced usage of consumable supplies.

Basic Policy

(Compliance with Laws and Regulations)

We will properly manage any chemical substance designated by relevant laws and regulations in respect of all our products and their manufacturing processes.
We will comply with the relevant laws and regulations, etc., of the local jurisdiction concerning drainage, sludge and emissions, etc., (i.e. environmental laws and regulations concerning air pollution, water pollution, waste, etc.) and will strive to achieve further improvement by using our voluntary standards when necessary.
We will obtain necessary permissions/approvals from applicable administrative agencies and make the required management reports.

(Matters We are Striving to Achieve)

We will make continuous efforts to achieve the effective utilization of energy/resources in order to promote energy/resource savings.
We will strive to achieve a continuous reduction in greenhouse gas emissions.
We will comply with laws and regulations on the proper disposal, recycling, etc., of waste and make efforts for activities to reduce the final amount of waste arising in the course of manufacturing our products, etc.
We will make efforts toward water resource conservation, and moreover, the effective use of water and the prevention of water contamination.

(Accountability)

With regard to our efforts on environmental practices and the results thereof, we will promote, in an orderly manner (i) the consideration of performance indicators, (ii) the recognition of results (including the development of necessary procedures) and (iii) an explanation of the content of our disclosures and efforts, etc., in order to fulfill our accountability regarding SEGA SAMMY’s responses.

SEGA SAMMY Group Overseas Bribery Prohibition Policy

Basic Concept

In recent years, legal regulations concerning bribery/corrupt practices have been strengthening internationally and clampdowns thereon have become stricter.

In light of the recent situation in which globalization of group business has been progressing and taking the above into account, we, the SEGA SAMMY Group, consider that dealing with overseas bribery risks is as an important task for our group companies.

We will comply with the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act as well as laws and regulations, etc., concerning the prohibition of bribery applicable to the countries/regions in which our group companies carry out their business and will prohibit the provision/acceptance of bribes to or from any public official or other person. Furthermore, we require those persons who execute all or any part of our business on our behalf, as well as the business partners of our group companies, to comply with the above-mentioned laws and regulations, etc., concerning the prohibition of bribery in order to eliminate bribery from the business in which our group companies are involved, as well as to ensure the transparent execution of their business.

*While we recognize the importance of dealing with bribery risks, regardless of whether they arise domestically or overseas, this policy is specifically established from the perspective of prohibiting overseas bribery, given the fact that legal regulations concerning international bribery/corrupt practices have been strengthening.

Basic Policy

(Compliance with Laws and Regulations)

We will not provide, offer to provide or promise to provide any bribe, directly or indirectly, to anyone, or accept any bribe from anyone.
We will fully understand and comply with the anti-bribery regulations and this policy through training, etc.

(Matters We are Striving to Achieve)

We will make payments to public officials only in accordance with appropriate approval procedures and carry out appropriate post facto confirmations (review procedures).
We will only execute business with agents and business partners who are legitimate and trustworthy and take appropriate procedures before executing business with them.
We will maintain internal controls on the retention of records and financial affairs, etc., so as to demonstrate our compliance with the anti-bribery regulations and this policy.
We will review this policy and the internal controls on a periodic basis and implement revisions/improvements thereof as necessary.
We will promptly make a report to the relevant department in the case of any of our officers, employees, agents and/or business partners being suspected of having breached the anti-bribery regulations and/or this policy, so as to enable measure to be taken in a timely and appropriate manner.