Basic Policy Against Antisocial Forces
COMPLIANCE
ExTech Co., Ltd. (the "Company") adopts this policy to sever all relationships with anti-social forces that threaten public order and safety and to respond firmly to improper demands. To protect all stakeholders and preserve corporate value, the Company works systematically and continuously to exclude anti-social forces.
Definition of Antisocial Forces
For purposes of this policy, "anti-social forces" means any individual or organization that falls within the following categories:
- Organized crime groups, members of organized crime groups, quasi-members of organized crime groups, companies related to organized crime groups, corporate racketeers
- Racketeers posing as social or political activists, and groups engaged in sophisticated organized crime
- Other persons equivalent to the preceding items
- Persons who have a close relationship with these persons
Basic Policy
1. Organizational Response
The Company will not leave responses to improper demands by anti-social forces solely to the person or department in charge. The President and Representative Director will be responsible for the response, and the Administration Department will coordinate an organization-wide response. The safety of officers and employees will take priority.
2. Cooperation with External Professional Organizations
To prepare for improper demands by anti-social forces, the Company maintains close relationships with external professional organizations, including the local police, the Prefectural Center to Promote Movements for the Elimination of Violence, legal counsel, and audit firms. The Company also collects relevant information and maintains procedures for prompt coordination and consultation when an incident occurs.
3. Severance of All Relationships Including Transactions
We will have no relationship whatsoever, including business transactions, with antisocial forces. In addition, we will screen business partners at the start of transactions and periodically to confirm that they have no relationship with antisocial forces. Should a business partner be found to be an antisocial force, we will promptly terminate the transaction.
4. Civil and Criminal Legal Response in Emergencies
The Company will take both civil and criminal legal action against improper demands or obstruction by anti-social forces. In cooperation with legal counsel, the Company will pursue civil remedies such as provisional injunctions and damages claims and seek criminal accountability by reporting matters to the police or filing criminal complaints.
5. Prohibition of Backroom Deals and Funding
Even if unreasonable demands by antisocial forces are based on misconduct in business activities or misconduct by employees, we will absolutely not engage in backroom deals to conceal the case. Furthermore, we will not provide funds or benefits to antisocial forces under any name.
Management System
Specific Implementation Measures
1. Pre-Transaction Screening
- Screening for ties to anti-social forces before starting a new business relationship (database searches, corporate registry checks, etc.)
- Periodic screening of existing business partners (at least once a year)
- Detailed due diligence on key business partners by external professional organizations
2. Anti-Social-Forces Exclusion Clauses
- Clearly state antisocial forces exclusion clauses in all transaction contracts
- Setting of representation and warranty clauses and transaction termination clauses
- Addition of anti-social-forces clauses to existing contracts through an amendment or memorandum
3. Implementation of Education and Training
- Training on elimination of antisocial forces for all employees (at least once a year)
- Implementation of antisocial response education in new employee training
- Implementation of practical training in sales and administration departments
- Maintenance and thorough dissemination of response manuals
4. Information Collection and Management
- Centralized management of information on antisocial forces
- Information collection from external professional institutions and internal database creation
- Recording and preservation of unreasonable demand cases, etc.
- Appropriate information management in consideration of the Personal Information Protection Act
5. Cooperation with External Professional Organizations
- Establishing cooperation with the local police and the Prefectural Center to Promote Movements for the Elimination of Violence
- Maintenance of a consultation system with corporate lawyers
- Information sharing with industry associations and other companies in the same industry
6. Maintenance of Internal Reporting System
- Establishment of a reporting contact point when a relationship with antisocial forces is discovered
- Ensuring anonymity and thorough protection of whistleblowers
- Prompt and appropriate response and investigation to reports
Compliance Declaration
To fulfill our corporate social responsibility, the Company will thoroughly disseminate this basic policy to all officers and employees and continuously implement initiatives to eliminate antisocial forces. Through these initiatives, we aim to improve corporate value and realize sound corporate management.
Revised: October 2025
ExTech Co., Ltd.
President and Representative Director