ADK GROUP ANTITRUST COMPLIANCE DECLARATION

All officers and employees (hereinafter collectively referred to as “Officers and Employees”) of the ADK Group recognize that they must conduct fair and equitable business transactions in all relevant countries and regions in the performance of their duties. They shall comply with the antitrust laws of the relevant countries and regions (referring to the “Act on Prohibition of Private Monopolization and Maintenance of Fair Trade” of Japan (including its enforcement orders, regulations, and guidelines) and the laws and regulations concerning the maintenance of fair competition in other countries or regions; hereinafter the same), this Declaration, and all internal regulations established by each group company based on these laws and the Declaration.

The ADK Group and its Officers and Employees shall not engage in any acts that violate antitrust laws, including cartels. No act that violates antitrust laws shall be justified by business customs, the professional status of the individual involved, the maintenance or expansion of business or transactions, or the pursuit of profit.

In interactions and information exchanges with competitors and other relevant parties, the ADK Group and its Officers and Employees shall not only refrain from involving themselves in the exchange of competitive information or any other acts that violate or may violate this Declaration, but shall also, upon discovering such acts by others, promptly report them to the company's legal department or other relevant divisions and follow their instructions.

The ADK Group shall create and maintain internal regulations and rules regarding antitrust compliance 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 antitrust compliance 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 antitrust compliance, including this Declaration, shall be subject to strict disciplinary action in accordance with the internal rules of the company to which they belong.