Compliance, Anti-corruption

In the "Penta-Ocean Construction Group Code of Conduct," we stipulate "Compliance with Laws and Regulations," ensuring strict compliance with laws and international rules in all countries and regions where we conduct business. In addition, we promote corporate behavior based on high ethical standards and sound judgment in line with social norms and ethics. Furthermore we define key policies such as "Fair Competition and Proper Transactions" and "Prevention of Bribery and Corruption", and strive to disseminate them across organizations, both at home and abroad. Promoting corporate behavior based on high ethical standards and sound judgment in accordance with social norms and ethics. We also specify and communicate both internally and externally matters such as "Fair Competition and Proper Transactions" and "Prevention of Bribery and Corruption." There were no significant legal violations in FY 3/25.

Based on the "Compliance Policy," Penta-Ocean Construction and Group companies have established the Risk Management Committee, and all executives and employees of the Penta-Ocean Construction Group are committed not only to comply with laws and regulations, but also to act in accordance with social norms and ethics, and always behave with integrity.

Action Guidelines for Proper Bidding

Our Response to Illegal Acts in Public Project Bidding

POC Group thoroughly communicated that the Company will never allow anyone, for any reason, to act in violation of the Anti-Monopoly Law, or the crime of obstruction of public contract-related auctions, etc., or other laws and regulations, and that executives and employees who commit illegal acts will be subject to strict penalties, including disciplinary actions in accordance with work regulations.

As part of measures to further promote thorough compliance, Penta-Ocean Construction Group established an outside office for consulting a lawyer, the Compliance Consultation Desk, apart from an internal contact point. Employees can report incidents that may conflict with laws, regulations, corporate ethics, and internal regulations, or a suspected violation of compliance. The consultation desk is available not only to executives and employees of POC Group, but also to all people affected by the Group's corporate activities. Anonymous reports are also accepted, and under the Whistleblower Protection Act, it is clearly stipulated that any disadvantageous treatment of whistleblowers is prohibited. The methods for using this contact point are posted on the intranet and website, posters are displayed at business offices and site offices, and this information is also communicated during compliance training. Additionally, we have established the Harassment Consultation Desk and the Human Rights Consultation Desk to receive consultations on various types of harassment such as sexual harassment, power harassment, and maternity harassment, as well as general human rights issues. For received consultations, after investigating the facts, we take appropriate actions such as guidance and disciplinary disposal in accordance with work rules and company regulations.

Compliance Training

POC Group provides various compliance training sessions, including anti-corruption training for all executives and employees to ensure that all of them comply with laws and regulations in conducting business activities, respect social norms and corporate ethics, and always act with integrity.

Main Training Programs for FY 3/25

Compliance Training for All Executives and Employees
In Japan, in addition to the "Declaration of Bid Rigging and Declaration of Compliance" based on past scandals, we also conducted training in accordance with our Group's "Code of Conduct" focused on compliance with laws and regulations such as the Construction Industry Act, Subcontract Act, and Antimonopoly Act. All domestic POC Group executives and employees received the training. At the same time, in all countries where we operate, we provided training focused on labor management, competition law, anti-bribery and corruption, harassment, and information asset management. All POC Group executives and employees in our overseas offices received the training.

Discussion-based Training for Managers
We provided discussion-based training for managers with a focus on cases of alleged internal and external misconduct, and violations of laws, etc.

Rank-based Training
We conducted rank-based training for younger employees and those eligible for promotion to learn about the Antimonopoly Act, risk management, and other subjects.

Anti-bribery and Legal Compliance Training

The Code of Conduct of POC Group includes "anti-bribery and anti-corruption" clause, which stipulates the prohibition of any acts that may constitute corrupt conduct including bribery. We communicate the Code of Conduct through rank-based compliance training programs to ensure its understanding by all officers and employees. In particular, with regard to bidding for public projects, we provide more in-depth training on bribery and the National Public Service Ethics Law based on actual cases to educate officers and employees so that they do not engage in illegal activities. We also provide Training for overseas employees on anti-bribery laws and other related topics, incorporating case studies to reduce compliance risks.

The Risk Management Committee established a framework that completely eliminates relationships with organized crime groups and other anti-social forces. It also manages and coordinates risks on this front, and has a system in place that enables the immediate response to the emergence of these risks. Furthermore, we carry out various initiatives that encompass our Group's overall business activities, such as providing a wide range of compliance training for executives and employees of POC Group. In relationships with business partners, our contract terms (such as "Construction Subcontract Agreement Terms" and "Sales of Goods Agreement Terms") include provisions for the exclusion of anti-social forces.