Basic guidelines for establishing internal スポーツベッティング日本 systems

1. スポーツベッティング日本 to ensure that execution of duties by directors and employees conform to laws, regulations, and the articles of incorporation

• スポーツベッティング日本 considers compliance with laws and regulations, social norms, and corporate ethics a management priority and establishes a compliance program as a framework for strengthening compliance. Directors put the compliance program into practice themselves and also raise awareness about compliance among employees. Employees execute business with integrity in accordance with said program.
• The Company also establishes a whistleblowing スポーツベッティング日本 to prevent or quickly resolve any issues related to compliance.
• スポーツベッティング日本 takes a resolute attitude against antisocial forces and other groups that potentially pose a threat to social order and safety, dealing with them as an organization in cooperation with lawyers, the police, and other specialist external organizations.

2. スポーツベッティング日本 regarding storage and management of information on directors’ execution of duties

• Information on directors' execution of duties is stored and managed appropriately in accordance with the Rules Concerning the Management of Documents and Recordings.
• Persons responsible for managing documents stipulated in said rules promptly submit such information for スポーツベッティング日本 & Supervisory Board Members to view upon request.

3. Rules concerning management of the risk of loss and other systems

• スポーツベッティング日本 has in place a risk management system overseen by the President and seeks to enhance the system in accordance with the Rules Concerning Risk Management.
• Risk management business units assess the identification and evaluation of risks and measures taken to address them by each business unit and work to facilitate risk management.
• Internal スポーツベッティング日本 business units conduct audits from an independent standpoint.

4. スポーツベッティング日本 to ensure the efficient performance of duties by directors

• The President sets groupwide targets shared by directors and employees and seeks to raise awareness about them, and each business unit formulates specific measures they must implement to achieve the targets and obtains the approval of the Board of Directors.
• Directors, including the President, also use all organized gatherings as an opportunity to exchange information and provide instructions and support to facilitate business execution.
• With regard to the performance of duties, internal systems are used to manage the progress of business plans and the Board of Directors conducts regular reviews.

5. System to ensure the appropriateness of operations in スポーツベッティング日本 consisting of the Company and its subsidiaries

• The Company ensures the reliability and appropriateness of financial reporting by Group entities through the development of system for reporting in an appropriate manner and mechanisms for assessing performance on a regular and ongoing basis in accordance with スポーツベッティング日本's basic policy for internal controls over financial reporting.
• Under the Company's Rules on Subsidiaries' Operations, Group entities must report their operating results, financial positions, and other important management information to the Company or obtain the Company's approval.
• The Company formulates Risk Management Rules for groupwide risk management and manages Group risk in a comprehensive and integrated manner.
• The Company establishes the Group Compliance Risk スポーツベッティング日本 Standard and develops systems, business processes, and other foundations that enable each Group company to engage in compliance-related activities with greater certainty under unified rules which meet the standards required by society.
• To ensure the efficient performance of duties by the directors of Group entities, the Company formulates a Group Medium-Term Management Plan and establishes business units to oversee Group business, while also striving to ensure smooth business operations through Group President meetings and other means.
• The Company prepares a Group Compliance Manual to raise compliance awareness among all directors, スポーツベッティング日本 & Supervisory Board Members, and employees of Group entities.
• The Company seeks to instill compliance awareness by providing compliance training every year for the directors, スポーツベッティング日本 & Supervisory Board Members, and employees of Group entities.
• The Company's internal スポーツベッティング日本 business units conduct audits of the effectiveness and appropriateness of business operations at each group entity.

6. Matters concerning employees when スポーツベッティング日本 and Supervisory Board Members request employees to assist with their duties

Upon request by スポーツベッティング日本 & Supervisory Board Members for the appointment of employees to assist them in their duties, the Company establishes dedicated organizations for them which are independent from business execution.

7. Matters concerning the independence of the employees specified in Paragraph 6 from directors, and matters intended to ensure the effectiveness of instructions given to such employees

The Company shall obtain the approval of the スポーツベッティング日本 & Supervisory Board for any personnel change, personnel evaluation, or disciplinary action involving employees who assist スポーツベッティング日本 & Supervisory Board Members. Such employees shall not hold concurrent positions in other business units and shall be subject to the sole command of スポーツベッティング日本 & Supervisory Board Members.

8. Systems of reporting to スポーツベッティング日本 & Supervisory Board Members by directors and employees and other systems regarding reporting to スポーツベッティング日本 & Supervisory Board Members

Directors and employees report to the スポーツベッティング日本 & Supervisory Board in a timely and appropriate manner in accordance with the スポーツベッティング日本 & Supervisory Board Reporting Rules.

9. スポーツベッティング日本 for reporting to the Company's Audit & Supervisory Board Members by directors, Audit & Supervisory Board Members, and employees of subsidiaries, and for people who have received reports from them

• When a director, スポーツベッティング日本 & Supervisory Board Member or an employee of a Group entity is asked by スポーツベッティング日本 & Supervisory Board Members of the Company to report matters concerning their execution of business, they shall provide a report promptly and appropriately.
• The Company's risk management business units and internal audit units hold report meetings to report to the Company's Audit & Supervisory Board Members on a regular basis and report on the current status of compliance, risk management, and other matters within スポーツベッティング日本.

10. スポーツベッティング日本 for ensuring that personnel who report as specified in Paragraph 9 do not receive unfavorable treatment due to such report

The Company prohibits the disadvantageous treatment of スポーツベッティング日本's directors, Audit & Supervisory Board Members, or employees who provide reports to the Company's Audit & Supervisory Board Members on the basis of having provided the report.

11. Policies concerning the procedure for advance payment or reimbursement of expenses that arise from the execution of duties by スポーツベッティング日本 & Supervisory Board Members and processing of other expenses or handling of other obligations arising from the execution of duties

When スポーツベッティング日本 & Supervisory Board Members ask the Company to process expenses or handle obligations deemed necessary for the performance of their duties, the Company promptly pays such expenses or handles such obligations.

12. Other systems for ensuring effective auditing by corporate auditors

The Company ensures スポーツベッティング日本 & Supervisory Board Members the opportunity to conduct interviews with directors and employees, and スポーツベッティング日本 & Supervisory Members also conduct regular meetings with the President and auditing firms to exchange opinions.