REGARDING THE ADK PARTNER HELPLINE
(WHISTLEBLOWING SYSTEM FOR BUSINESS PARTNERS)

The ADK Partner Helpline is designed to enable business partners who become aware of any conduct by officers and employees of the ADK group that violates laws and ordinances related to the ADK Group’s business operations, or that violates ADK Group’s internal rules and regulations, or other discipline standards equivalent thereto, (hereinafter referred to as “Misconduct”), to report such incidents to our company. The purpose of this initiative is to prevent and rectify Misconduct, promote corporate self-purification, and thereby advance the compliance management of the ADK Group.

If any instances of Misconduct or suspected Misconduct (whether committed/ attempted) by officers or employees of the ADK Group is discovered in connection with business transactions, we kindly ask that all our business partners should report it promptly in accordance with the following guidelines.

• Internal Contact for ADK Partner Helpline
  By Post: Partner Helpline, Audit Division, ADK Holdings Inc.
  1-23-1 Toranomon, Minato-ku,Tokyo 105-6312, Japan
  By Email: P-helpline_prj@adk.jp
• External Contact for ADK Partner Helpline
  By Post: Attn: Attorney in charge of ADK Partner Helpline, TMI Associates
  23rd Floor, Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku, Tokyo 106-6123, Japan
  By Email: adkpartner-helpline@tmi.gr.jp

• When submitting a report, please clearly state the reporter’s name, the name of company and department to which he/she belongs, and contact information (hereinafter “Reporter Information”).
  However, the reporter is also able to submit a report without disclosing any Reporter Information to the internal or external contacts listed in (1) (hereinafter “Anonymous Reporting”). In such cases, the method of communication will be determined through discussion between the person in charge at each contact and the reporter.
• When submitting a report, please attach materials that serve as grounds or evidence for the facts related to the report to the extent possible.
• Please note that a report may not be accepted as a valid compliant in cases where investigation is difficult (e.g., the content uses codes, hints, or riddles that are difficult to understand and the reporter cannot be reached), where the matter has already been resolved, where facts cannot be verified due to lack of cooperation from the reporter, or where the content is clearly false or clearly does not constitute Misconduct.
• When submitting a report, please do not include any information that falls under the “Trade Secrets” (*) of the company or organization to which the reporter belongs. *Trade Secrets refer to “technical or business information useful for business activities, such as manufacturing or marketing methods, that is kept secret, and is not publicly known,” as defined in Article 2, Paragraph 6 of the “Unfair Competition Prevention Act.”

• Upon receipt of a report, our specialized organization (hereinafter “Investigating Organization”) will be responsible for the investigation.
• No investigation will be conducted for the purpose of identifying the identity of an anonymous reporter.
• The Investigating Organization may outsource the investigation to a third party (including, but not limited to, external contact).
• Personnel scheduled to be involved in the investigation, such as those in charge of internal and external contacts, the Investigating Organization, and its secretariat, shall, in principle, not participate in the investigation or response to reports concerning matters in which they are personally involved or have any other conflicts of interest.
• During the investigation, our Investigating Organization may contact the reporter to verify facts.
• The details of the report shall be managed with due care and will not be disclosed within or outside the ADK Group beyond the extent necessary for the investigation.
  If necessary for the investigation, the company to which the reporter belongs may be contacted for fact-checking based on the details of the report.
• Personal information of the reporter will be handled strictly in accordance with the “Act on the Protection of Personal Information” and our Privacy Policy.

• In principle, the reporter will be notified of the decision on whether or not to conduct an investigation. Furthermore, if an investigation is conducted, the reporter will also be informed of the results of the investigation and actions taken based on those results, as well as the determination regarding the veracity of the reported facts and whether there has been a violation of laws or internal regulations. However, in the case of Anonymous Reporting, or if the contact information is unknown or unreachable, or due to other unavoidable circumstances, it may not be possible to provide notification of the investigation results.

• The ADK Group will not subject any reporter to disadvantageous treatment on the grounds of having made or attempted to make a report.
• If a reporter is subject to disadvantageous treatment, he/she may contact the internal or external reporting contact to request a response.
• Any person who becomes privy to information regarding reports, including persons in charge of internal and external reporting contacts, as well as the Investigating Organization through the course of their duties shall maintain the confidentiality of such information and must not disclose it to third parties without the reporter’s consent or other justifiable reasons.