Compliance Declaration

The Lion Group's strong reputation for trustworthiness has been built through decades of hard work by its employees. The trust the Group enjoys has been a key driver of its growth and development. As our operating environment continues to undergo profound changes, we strongly believe that it is necessary to clearly lay out the principles that anchor our behavior, which we have honed over years of operations, in a Code of Conduct. We must create and maintain a framework that will ensure that each and every person working in the Lion group understands and is able to carry out their responsibilities.

Compliance means obeying laws and regulations as well as maintaining a strong ethical grounding in order to satisfy the expectations and needs of customers and other stakeholders while fulfilling our role as a public entity. We regard ethics as meaning, broadly, doing what is right. In concrete terms, we see this as rooted in being honest, observing social mores, not antagonizing others, and thinking of others as we think of ourselves. Based on this understanding, we established the Lion Group Charter for Corporate Behavior in 2003.

We have updated the Lion Group Charter for Corporate Behavior in light of changes in society. The Behavioral Guidelines contained therein now more clearly define our stance with regard to providing safe, secure products and services, addressing environmental issues and other topics.

We hereby once again declare our commitment to upholding the Lion Group Charter for Corporate Behavior and ensuring that the Company is useful and valuable to society.

January 1, 2008

Compliance Consultation/Notification Window (AL Heart Hotline)

In LION Group (hereinafter, the “Group”), when the Group's employees or customers become aware of any conduct in actual or suspected violation by the Group or its employees of laws or corporate ethics (LION Group Charter for Corporate Behavior or Behavioral Guidelines), or otherwise wish to consult about any other ethical problems, they are entitled to consult with or notify to the in-company or external notification (whistleblowing) window (AL Heart Hotline).

Notification (Whistleblowing) Window

1. Person responsible for corporate ethics in the company
Adressee of documents 1-3-7, Honjo, Sumida-ku, Tokyo 130-8644 Japan
“Attn: Person responsible for corporate ethics, Auditing Office, Lion Corporation”
Email address (for this purpose only) ethics@lion.co.jp
2. External attorney
Adressee of documents 5F, Eiha-shinkawa, 1-5-17, Shinkawa, Chuo-ku, Tokyo 104-0033 Japan
“Attn: Attorney-at-law, Shuji Yamaguchi Okabe & Yamaguchi Counselors at Law”
Email address (for this purpose only) al-hot@olo.gr.jp

Persons eligible to use the Hotline

  • The Hotline is available not only for the Group’s regular employees but also for the Group’s all workers including casual employees (such as part-time employees), dispatched employees and contracted employees as well as those who have transactional or any other relationship with the Group.

Method of consultation and notification

  • To identify the contents precisely, if possible, please consult or notify in a document or by email.
  • To enable sufficient and prompt identification of facts as well as feedback of investigation results and future actions, please disclose the identity of the notifying person (name, department, company name). Note that, in the event of notification on an anonymous basis, the factual investigation may become insufficient, and further that such feedback will not be possible. Also, when notified to an external attorney, the notifying person may request for masking of his/her name when being transferred to the person in charge of corporate ethics in the company.
  • As regards the contents of such consultation and/or notification, please describe the relevant acts of violation of laws or corporate ethics in as much detail as possible, by specifying “when” “where” “who” “what” “for what purpose” “how”, and “what are the consequences”.
  • Please use the following template as the format for notification.

Flow after receiving consultation and/or notification

  • We will promptly verify the facts through the consulting and/or notifying person, and then evaluate the seriousness of the factual details. Depending on the nature of the case, it will be reported to the top management.
  • After factual investigation, if certain non-compliant acts have been established, we will, under the top management’s knowledge sharing and instructions, take steps towards settling the shape, resolving the issues, and then taking remedial actions for prevention of recurrence. Also, the violators will be strictly sanctioned.
  • The window receiving the consultation and/or notification will feedback the relevant consulting and/or notifying person.

Protection of notifying persons, etc.

  • The privacy of the consulting and/or notifying person and the person targeted in the notification, etc. will be protected.
  • The persons in charge of investigation and remedial actions will ensure that they keep the existence of and the contents of consultation and/or notification in strict confidence.
  • You will not suffer any disadvantage due to your cooperation with the investigation, etc.