Conducting Business Activities with Integrity for All Stakeholders

Goals and KPIs

2030

Goal

Create an organization that practices our value of “Integrity Driven (stay true to our team, customers, and society),” and provide an environment where each and every employee can take on the challenge of achieving our mission with peace of mind

(Important Actions to Achieving Goal)

1. Create an organization in which all employees have correct knowledge and high awareness of compliance based on values and principles
2. Create an organization that can respond quickly and appropriately to compliance issues when they arise

KPIs

1. Number of compliance issues: 0/year (target: consolidated group)
   Establishment of an effective compliance structure
2. Number of whistle-blowing cases (cases/year, monitoring indicator; target: consolidated group)
3. Compliance training participation rate: Maintained at 100% by FY2024 (target: consolidated group)

2024

Goal

Create a base to achieve our value of “Integrity Driven (stay true to our team, customers, and society)”

(Important Actions to Achieving Goal)

1. Regularly update guidelines such as “Code of Conduct” and “Internal Rules” and implement activities to spread them
2. Provide regular education on compliance and other matters to all executives and employees
3. Create an open organizational culture (including implementing regular external compliance surveys and developing/operating an internal reporting system)

Initiatives

• Establishment of an effective compliance structure (appointed an officer responsible for compliance as the person responsible)
• Compliance training participation rate: 86.5% for consolidated group, 100% for kubell alone
  * Some employees did not undergo training due to the establishment of kubell partner Co., Ltd. in April 2024; subsequently, we followed up on this issue and the current consolidated participation rate is 100%.
• Number of whistle-blowing cases: 10

Approach and System

Approach to Compliance

We believe that it is essential not only to comply with laws and regulations, but also to prioritize the interests of society and our stakeholders in order to continue creating value for society and achieve sustainable growth. Without such integrity, there will not be trust between colleagues on the same team, which will make it difficult to demonstrate and sustain superior performance. It will also be impossible to build strong relationships with our business partners.
For this reason, kubell Group has made “Integrity Driven” one of our values. We strive to become an organization that stays true to all of our stakeholders.

To achieve this, kubell Group uses a risk-based approach—a basic approach for dealing with compliance—to identify compliance-related risks inherent to our businesses and organizations, and implement measures according to those risks.

Compliance Structure

We are committed to embodying our value of “Integrity Driven” and implementing robust compliance management. To this end, the Board of Directors—as well as the officer responsible for compliance appointed by the board—determines policies and establishes a compliance structure to ensure the legality of all executive and employee decisions and activities as well as to fulfill our social responsibilities. It also approves and reviews necessary activity plans and both deliberates and approves policies for addressing any issues that are found.
Furthermore, we have established a Compliance Committee, consisting of members approved by the Management Meeting, as a permanent committee that is independent of the management and each department. Under the direction of the officer responsible for compliance, this committee formulates and implements compliance activity plans for each individual risk, operates an internal whistleblowing system, conducts compliance training for all executives and employees, and carries out other activities as designated by internal regulations. In the event that a compliance incident occurs, the committee handles matters such as coordinating between parties concerned and filing complaints at the request of the whistleblower, investigating complaints, and remedial measures for victims.

Compliance Structure Chart

Internal Whistleblowing System

At kubell Group, since April 2018, we have introduced and are operating an internal whistleblowing system to prevent law and regulation violations, misconduct, and other issues, as well as to quickly collect information and formulate responses. The Compliance Committee staff and outside legal counsel have been designated as points of contact, and all executives and employees of kubell Group have been informed of the system. Details of whistleblowing cases are reported to the Compliance Committee, discussions and investigations—with the involvement of lawyers as necessary—are conducted, and details regarding compliance violations are reported to the Management Meeting.
Furthermore, this system maintains whistleblower confidentiality and protects their personal information. At the same time, we established regulations that protect whistleblowers and ensure they are not disadvantaged, taking thorough measures to protect whistleblowers.
In fiscal year 2024, there were 10 whistleblowing cases, and there were no reports regarding severe compliance violations.

Internal Whistleblowing System

Main Initiatives of Fiscal Year 2024

Conduct of Compliance Training

As part of our compliance measures, we conduct compliance training for all employees. Based on the compliance training that is conducted twice each year, we also develop training programs for each grade—such as new employees, mid-career hires, and managers—as well as theme-based training programs.
We will continue to aim for a compliance training participation rate of 100% for both kubell and the consolidated group in fiscal year 2025 and beyond.

* Training was not conducted for certain group companies due to the establishment of kubell partner Co., Ltd.; subsequently, we followed up on this issue at the start of 2025 and the consolidated participation rate is 100% as of July 2025.