DYNAM JAPAN HOLDINGS

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Compliance

DYNAM JAPAN HOLDINGS takes steps to develop organizations and a corporate culture that prioritize compliance, to ensure that it meets the expectations of customers and society and fulfills its corporate social responsibilities.

The DYNAM JAPAN HOLDINGS Group Charter of Corporate Behavior represents the corporate behavior and commitment that are shared by all employees.

The raison d’être of a company is to achieve sustained growth in line with the expectations of stakeholders, including shareholders, managers, employees, partners, financial institutions, and customers, and to achieve a scale and a level of reliability that enable it to contribute to society. All employees of the DYNAM JAPAN HOLDINGS Group share this principle.

The DYNAM JAPAN HOLDINGS Group calls the stakeholders described above “partners in trust.” We are committed to strengthening our relationship with these partners through our business activities, so that we can grow based on a far-reaching vision. As it grows, the Group will consistently fulfill the roles expected of it by each stakeholder, to ensure that stakeholder trust also grows.

Trust, however, is fragile, and even a momentary lapse of focus can damage it forever. To ensure that it can continue to conduct its business without compromising that trust, the DYNAM JAPAN HOLDINGS Group has adopted new internal control systems to improve its operations. These systems also continually clarify and eliminate factors that have the potential to lead to misconduct or violations of laws and regulations.

All DYNAM JAPAN HOLDINGS Group employees, including those working in the field, constantly take actions they know that will help improve their work. These operational improvement activities will continue endlessly. Through these initiatives, each member strongly believes that the DYNAM JAPAN HOLDINGS Group can achieve superior operating results and more effectively contribute to society.

Compliance Promotion Structure Rooted in Actual Operation Fields

A Group Internal Control Committee has been established to develop and manage a structure that promotes compliance from an inter-Group perspective.

The Group Internal Control Committee examines policies related to the Group’s compliance management and execution plans of internal control, and monitors progress in the development of compliance and internal control structures.

Structure of the Compliance Promotion

Structure of the Compliance Promotion

Establishing a hotline to promptly identify and solve issues

In principle, employees of the DYNAM JAPAN HOLDINGS Group are to report and consult with their managers when they become aware of activities that violate the DYNAM JAPAN HOLDINGS Group Charter of Corporate Behavior. However, to promptly identify and solve such issues that are difficult to report or consult on internally, a DYNAM JAPAN HOLDINGS Hotline (a whistleblowing system) has been established using an outside law firm and is available to all Group companies.

Not only the Group’s employees, but also other workers, such as dispatched workers and contractors, as well as all family members of the employees, including those of dispatched workers, are encouraged to use the hotline to report activities that violate the DYNAM JAPAN HOLDINGS Group Charter of Corporate Behavior or that may potentially create problems in the future.

Each issue that is presented through the hotline is examined by attorneys and the departments of the Group companies in charge, while carefully protecting the privacy of all related parties. If any particular problems are found, those in charge take actions such as issuing improvement orders, and confirm later that the problems have been resolved and that full measures to prevent any reoccurrence have been carried out. They also report the matter to the Audit Committee.

Protection of Whistleblowers

As the DYNAM JAPAN HOLDINGS Group established a hotline, under its internal rules, it prohibits whistleblowers from being treated unfairly. It also has established Whistleblowing Rules that state such obligations as following up on whistleblowers after the incidents to thoroughly enforce the rules for protecting whistleblowers.

Flow of Handling of the DYNAM JAPAN HOLDINGS Hotline

Flow of Handling of the DYNAM JAPAN HOLDINGS Hotline

Thorough Implementation of Fair Business Activities

The basic premise of the operations of the DYNAM JAPAN HOLDINGS Group is to comply with laws and regulations, including the Law on Control and Improvement of Amusement Business (the Amusement Business Law), and to carry out fair business activities. Accordingly, the Group has developed operating manuals for its operation sites, and revises and manages these manuals to respond to revisions in laws and changes in the business environment.

The Group also strives to ensure that all halls nationwide comply with the related laws and regulations by establishing information sites related to regulations concerning sales methods and advertising restrictions, and publishing guidelines.

Moreover, the Group makes its best efforts to raise awareness and knowledge about compliance by publishing Rules on Compliance with the Anti-Monopoly Act, Rules on the Prevention of Unfair Competition Concerning Trade Secrets, Rules on the Prevention of Insider Trading, and other rules on the internal intranet site.

Prohibition of Bribery and Other Activities to Ensure the Transparency of Business Activities

The DYNAM JAPAN HOLDINGS Group confirms in the DYNAM JAPAN HOLDINGS Group Charter of Corporate Behavior that the Group will develop legally, socially, and ethically sound, reasonable, and equal relationships with business partners to ensure that it can economically grow together with its business partners. Accordingly, the Group prohibits its employees from receiving or offering entertainment or gifts from or to organizations, companies, individuals, or any other parties, and ensures that they maintain a sound and transparent relationship with such parties in compliance with laws and regulations.

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