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Basic Policy of Internal Control System

1. System for ensuring that the performance of duties by directors and employees complies with laws and regulations and the articles of incorporation

  1. To ensure that the execution of duties by JPR officers and employees complies with laws and regulations and the articles of incorporation, and under sound social norms, we will establish and disseminate corporate conduct guidelines and other regulations related to compliance systems.
  2. We will establish a department in charge of compliance to promote company-wide compliance efforts. In addition, mainly through this department, in order to thoroughly disseminate and implement the regulations concerning compliance, we will regularly conduct compliance training for directors and employees.
  3. We will establish a department in charge of internal audits and inspect the status of compliance in cooperation with the department in charge of compliance and will report important matters to the Board of Directors on a regular basis.
  4. A helpline contact will be established within the company as a reporting system when employees and others discover acts that violate laws and regulations and the articles of incorporation.
  5. We will establish a basic policy for dealing with anti-social forces, appropriately coordinating with external organizations such as the police, resolutely responding to anti-social forces, and securing/improving an organizational system to block all such relationships.

2. System for storing and managing information related to directors' performance of duties

  1. Information related to the execution of duties by directors shall be appropriately recorded and saved in documents or electromagnetic media based on laws and document management regulations.
  2. Directors and audit & supervisory board members can view documents containing information related to the execution of duties by directors, when necessary.

3. Regulations and other systems for managing the risk of loss

  1. Based on the risk management regulations, we will understand the risks related to business execution, manage them, and take measures to prepare for a crisis.
  2. The management council, in cooperation with the department in charge of internal audit, promotes company-wide risk management and shares necessary information, reporting to the board of directors on the status of risk management activities and making proposals as necessary.
  3. In the event of a serious crisis, the emergency response headquarters headed by the CEO will be promptly organized to take action to respond to the crisis and promptly resolve it.

4. System to ensure efficient execution of duties by directors

  1. In order to clarify the duties and authorities of directors, in addition to the regulations of the board of directors, we will establish organizational regulations, division of duties regulations, and duty authority regulations, and review them regularly as necessary.
  2. The board meetings will be held in accordance with the regulations of the board of directors. Matters that are important for management are deliberated in advance by the management committee, which is composed of full-time directors, and the board of directors will make decisions after deliberation.

5. Ensuring proper business operations in the corporate group consisting of the stock company and its parent company and subsidiaries

  1. We will establish common corporate action guidelines for the JPR Group, and make sure that all executives and employees of the group are thoroughly informed of the spirit of compliance.
  2. The department in charge of internal controls of the entire JPR Group will be the general affairs department, and measures will be implemented to enhance the effectiveness of internal controls at each group company. Necessary guidance and support will be provided to each group company.
  3. Group company management rules are established to require approval from the departments in charge under the JPR division of duties for certain important management matters before the resolution of the board of directors, and those that meet certain standards will be in the JPR the board of directors' resolution matters.
  4. The department in charge of JPR’s internal auditing conducts internal audits of subsidiaries based on internal auditing rules and group company management rules.
  5. A group reporting system will be established so that JPR Group executives and employees can report directly to the JPR helpline.

6. Matters concerning employees when an audit & supervisory board member requests the appointment of an employee who should support his/her duties

JPR will promptly allocate the appropriate personnel when there is a request from the audit & supervisory board members regarding the placement of employees who should assist the duties of the audit & supervisory board members.

7. Matters concerning the independence of the employees in the previous item from directors

  1. Employees who should assist the duties of audit & supervisory board members shall not concurrently serve as employees of other departments, and shall not receive commands and orders from persons other than audit & supervisory board members.
  2. Regarding personnel changes and evaluations of employees who should assist the duties of corporate auditors, the consent of corporate auditors is required in advance.

8. Establishment of reporting to audit & supervisory board members by the board of directors and employees and other systems for reporting to audit & supervisory board members

  1. The directors and employees shall report at any time to the meetings of the board of directors attended by the corporate auditors and other important meetings regarding the status of execution of their duties.
  2. Directors and employees shall immediately report to the audit & supervisory board members any findings that may cause significant damage to JPR, such as violations of laws and regulations.

9. Other systems to ensure effective audits by audit & supervisory board members

  1. Directors will regularly meet with corporate auditors to exchange opinions on issues that the company should deal with, the status of audit environment improvement, and other important issues.
  2. Directors and employees will cooperate with corporate auditors when they request a report on JPR business or when corporate auditors investigate the status of JPR's business and assets.
  3. The corporate auditors can cooperate with the department in charge of internal audits and request assistance if necessary.
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