ADK GROUP ANTI-BRIBERY DECLARATION

All officers and employees (hereinafter collectively referred to as “Officers and Employees”) of the ADK Group shall comply with the laws and regulations concerning anti-bribery in the relevant countries and regions, as well as this Declaration and all internal regulations established by each group company based on it in the performance of their duties.

The ADK Group and its Officers and Employees shall not, whether directly or indirectly, provide money or any other benefits to public officials or other business entities for the purpose of obtaining improper business advantages, nor shall they offer or promise such benefits.

The ADK Group and its Officers and Employees shall not, whether directly or indirectly, receive any improper benefits in connection with their duties, nor shall they request or promise such benefits.

The ADK Group and its Officers and Employees shall not issue instructions that constitute or could be construed as bribery through third parties providing services on their behalf including, but not limited to, agents, contractors, intermediaries, and consultants, nor shall they tolerate any bribery or acts that may constitute bribery by such third parties.

The ADK Group and its Officers and Employees shall record all transactions fairly and accurately in accounting books and appropriately maintain related documents.

The ADK Group shall conduct regular audits of relevant businesses to ensure continuous compliance with this Declaration and laws and regulations concerning anti-bribery.

The ADK Group shall create and maintain internal regulations regarding anti-bribery that reflect the spirit and fundamental principles of this Declaration, taking into account the social conditions and the status of enforcement of laws and regulations related to anti-bribery surrounding each group company. Furthermore, the ADK Group shall establish its own systems to ensure that these regulations are observed by its Officers and Employees, as well as by external business partners and other stakeholders who collaborate with the ADK Group.

In the event that an act violating or potentially violating this Declaration is discovered, the ADK Group shall conduct a rigorous internal investigation, cooperate fully with investigations by relevant authorities, and take necessary corrective measures. Furthermore, any Officers and Employees who violate the regulations regarding anti-bribery, including this Declaration, shall be subject to strict disciplinary action in accordance with the internal rules of the company to which they belong.