Compliance Policy

The Cosmo Energy Group Management Vision is, “Striving for an infinite tomorrow, developing sustainably in harmony with humanity, society, and our planet.” As part of our efforts to achieve this vision, we recognize that it is imperative for the Group to comply with all relevant laws and regulations, internal rules, and social norms. Accordingly, the Cosmo Energy Group Code of Conduct requires all officers and employees to act in good faith with high ethical standards. This Compliance Policy is based on our Management Vision and Code of Conduct and outlines our basic approach to operating our business with an emphasis on compliance.

We comply with relevant laws and regulations, carry out fair corporate activities in good faith without deviating from social norms, and strive to foster a corporate culture that values high ethical standards and compliance.

We comply with laws such as Japan’s Act against Unjustifiable Premiums and Misleading Representations and Unfair Competition Prevention Act, eliminate any unfair trading practices, and promote free and fair competition. In promotional materials, we never utilize exaggerated expressions or explanations that may mislead the public.

We do not improperly acquire the trade secrets of other companies for any reason. Also, we do not use the trade secrets of other companies, if we know that they were or may have been acquired fraudulently.

We do not give or receive entertainment or gifts that deviate from social norms or internationally accepted conventions. Also, we never give or receive inappropriate entertainment or gifts for the purpose of providing personal or other improper benefits.

We never provide unsuitable entertainment, gifts, benefits or other financial benefits to public officials or those in similar positions.

When making political contributions or donations to various organizations, we use official channels in compliance with relevant laws and regulations. In addition to never engaging in bribery, benefit provision or illegal political contributions, we do not take part in activities that could be seen as a sign of inappropriate relationship with politicians or public officials. We strive to build sound and transparent relationships with government bodies.

We never form relationships with organized criminal elements or groups. We do not grant them any benefit whatsoever. Also we never conduct transactions with these groups or with any entities associated with them, nor do we take part in money laundering.

We properly follow customs clearance procedures for exports and imports, as well as the examination procedures for security export control. In the event economic sanctions are placed on a relevant export destination, we follow the guidelines issued by the Japanese government.

In all situations, we do not engage in any private monopoly, cartels or other forms of unfair restriction of trade. We do not engage in unfair transaction practices, refuse contract delivery, delay payment, or impose unreasonable terms of business and we strive to maintain and promote free and fair competition.

We request business partners to comply with relevant laws and regulations. If a business partner commits a legal violation with a substantial social impact and does not rectify the situation, we take appropriate measures such as terminating the business relationship.

We recognize that the intellectual property rights owned by the Group are important assets of our Group, and will strive to preserve those rights and use them effectively. We also respect the intellectual property rights owned by other companies and take steps to avoid infringing those rights.

We employ a whistleblower system (Corporate Ethics Consultation Helpline) and strive to ensure early detection and rectification of potential legal violations and similar activities. Accordingly, we make the helpline available not only to officers and employees of the Group, but also to business partners and other parties involved in the Group’s business activities.

We actively share this policy with officers, employees, business partners and other stakeholders. We fully educate all of our officers and employees on this policy to ensure that it is properly integrated into the business activities of the entire Group.

We disclose on our website and in reports the progress and results of our compliance efforts based on this policy.

Established: February 10, 2022