Dentsu Group Charter of Corporate Conduct

Dentsu Inc. and its subsidiaries (the “Dentsu Group”) believe that the Dentsu Group has a responsibility to voluntarily address social issues, by complying with all applicable laws and regulations, providing the highest standard of occupational health and safety, upholding human rights, contributing to the public good and protecting the natural environment, all the while taking into account all stakeholders. The Dentsu Group Charter of Corporate Conduct is a self-determined code of conduct to be followed by our management and employees, to ensure the highest level of business ethics and integrity. Each company in the Dentsu Group will adhere to this Charter.

1. Basic compliance matters

[Strict legal compliance and corporate ethics]

In performing our business activities, we will comply strictly with all applicable laws and regulations, uphold societal and cultural standards, and build our corporate ethics so that we act with the utmost integrity.

(1) Our employees will observe applicable laws and regulations and endeavor constantly to act with good sense and integrity.

(2) We will implement a system of training and consultation to support employee compliance with applicable laws and regulations and create a solid foundation of corporate ethics.

[Timely and proper disclosure of corporate information]

We will disclose all necessary information to stakeholders in a timely and proper manner.

(1) We will disclose appropriate information to our various stakeholders, including our shareholders, clients and business partners.

(2) We will endeavor to disclose such information in a way that is fair, timely and easy to understand.

2. Business conduct

[Creating new value]

Through our communications activities with our clients, business partners, and society, we will create new value and contribute to the social and cultural development of our society.

(1) We will contribute to the development of society by providing superlative communications services and acting as a trustworthy partner for our clients, business partners and consumers.

(2) Through our communication activities, we will create, enrich and accumulate intellectual property that contributes to the social and cultural development of our global society, including Japan.

(3) In providing communications services, we are determined to comply with the applicable laws and social standards, and to respect human rights. We will not engage in any activity that may have an adverse effect on public order, morals or safety.

[Fair competition, fair trade and proper business conduct]

We will conduct our business in accordance with the principles of fair competition and fair trade.

(1) We will comply with all applicable laws and regulations.

(2) We will maintain a clear system for the appointment of suppliers. Our selection process will take due account not only of economic factors, but also policy and performance factors such as legal compliance and environmental protection.

(3) We will strictly manage, with the highest standard of confidentiality, key information and intellectual property held by the Dentsu Group, or entrusted to us by our clients and business partners.

(4) We will maintain ethical relationships with governments, political parties and administrative bodies.

[Proper management of risks affecting our business continuity]

We will properly manage any risk that might cause damage or harm to, or threaten the continued existence of, any Dentsu Group company. We will also endeavor to minimize the effects of such risks.

(1) We will prepare, in advance, action plans to deal with the prevention and handling of natural disasters and accidents that might cause loss to any Dentsu Group company, including fires, floods, earthquakes and accidents involving airplanes, motor vehicles or similar, and we will respond promptly to any such emergency.

(2) We will respond decisively to any internal or external activity that might hinder the fulfillment of our social responsibilities, or that might cause harm to any Dentsu Group company.

(3) We will not have dealings with any unlawful organization, group or person.

[Proper protection of shareholder interests]

We will protect the interests of our shareholders as we serve the public interest.

(1) We will carry out sound corporate management and protect the interests of shareholders.

(2) We will maintain excellent investor relations and promote dialogue with shareholders.

(3) Our general meetings of shareholders will be conducted in a lawful and proper manner.

(4) In order to avoid any activity that constitutes or might be perceived to be insider dealing, we will maintain internal rules and ensure that all parties concerned are fully aware and familiar with them.

3. Socio-environmental concerns

[Environmental responsibilities]

We will contribute actively to the protection and improvement of the global environment.

(1) We will properly evaluate the effects of our corporate activities on the environment and take measures to reduce any potential harm that such activities may cause.

(2) We will contribute to environmental amelioration and endeavor to develop and promote environmentally friendly communication services.

[Social responsibilities]

As responsible corporate citizens, we will actively participate in activities that contribute to our society.

(1) Through our communications activities, we will identify issues of importance to society and work cooperatively to resolve them.

(2) We will respect the autonomy of employees and encourage them to use their skills and experiences to contribute to society.

(3) We will work with external bodies and individuals offering valuable or special services in order to enhance our contribution to society.

[Global business activities]

When developing our global business, we will respect the individual culture and traditions of each country and contribute to local development.

(1) We will respect the culture, traditions and societal values of each country and comply with its laws and regulations, as well as international laws and standards.

(2) When developing our global business, we will contribute to the development of the relevant country through cooperation, such as providing expertise, training and staff development, and by deepening friendly relationships with related companies and organizations, as well as society as a whole.

4. Employee relations

[Maintenance of a good work environment]

We will respect the human rights of our employees, maintain and improve their work environment, and develop their skills and abilities.

(1) We will respect the human rights and privacy of our employees, and will be an equal opportunity employer.

(2) We will respect employment laws and regulations and maintain a safe and easy-to-work-in work environment.

(3) We will encourage employees to take the time and space necessary to appreciate their work and lives.

(4) We will provide our employees with the necessary means to improve their skills and abilities and support their career development.

(5) We will endeavor to create a work environment where employees can work enthusiastically and demonstrate their originality and unique abilities.

5. Implementation of the Charter of Corporate Conduct

[Understanding and observing the Charter of Corporate Conduct]

The management and employees of each Dentsu Group company will endeavor to fully understand and observe the Charter of Corporate Conduct.

(1) Demonstrating leadership by taking the initiative and setting an example to others, management will adhere to the Charter of Corporate Conduct and work to ensure that all employees are completely familiar with the Charter of Corporate Conduct.

(2) Management will regularly evaluate the degree to which the Charter of Corporate Conduct is understood and observed.

(3) Each employee will be aware of his or her responsibility to follow the Charter of Corporate Conduct and will act accordingly.

[Sound implementation and further improvement]

We will apply and maintain internal control procedures to ensure compliance with and understanding of the Charter of Corporate Conduct and implement further improvement.

(1) Through effective internal control procedures, we will endeavor to ensure compliance with the Charter of Corporate Conduct and promote proper and effective business operations.

(2) Through various programs for our managers and employees demonstrating the Charter of Corporate Conduct in practice, we will make every effort to ensure a solid foundation of corporate ethics.

(3) We will continue to respond to changing social conditions by revising and improving the Charter of Corporate Conduct as appropriate.