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Basic Philosophy Regarding Internal Controls

We strive to ensure that documentation of the corporate philosophy, our standards of conduct as a company, and relevant compliance manuals are made accessible throughout the company. Top management is mandated to clarify policy, making it clear that compliance with laws and corporate ethics form the basic foundation of the company's management. The Dunlop Sports Committee for Compliance, headed by the President, identifies compliance issues throughout the company, conducts assessment and analysis, formulates countermeasures to such risks, and familiarizes employees with the findings.

We have prepared the following system of guidelines to ensure appropriate business practices.

  • Establish a system in which employees can directly report or consult on compliance issues by creating a help desk in compliance with the Whistleblower Protection Act.
  • Record and properly manage information concerning the execution of duties of directors, in accordance with document control regulations and guidelines for information security.
  • Management risks, including those relating to quality control, law, environment, credit, accidents, and disasters, etc., which may significantly affect the company's business operations, are considered by a central risk management response committee; in addition, the corporate planning division will respond to risks at all levels of the organization through collaboration with the affected departments. As necessary, this may include seeking advice or guidance from legal counsel.
  • Adopt a system in which executive officers can institute flexible business practices to response to customer needs and environmental changes.
  • In addition to setting a mid-term management plan regarding the efficiency and performance of each department, establish targets in the budget meeting and assess and analyze the levels of achievement each month in the Dunlop Sports meeting.
  • Share standards for Dunlop Sports Co. Ltd. corporate behavior with all affiliated companies, and encourage respect and compliance with the law in all Dunlop Sports Group business operations.
  • Assign employees to assist Audit & Supervisory Board Members in order to improve the effectiveness of their work. In addition, full-time Audit & Supervisory Board Member shall attend important Dunlop Sports meetings, and matters involving risk shall be properly reported by the department heads or president to the Audit & Supervisory Board Members.

In order to eliminate anti-social forces, Dunlop Sports:

  • Does not condone any kind of activity contrary to the interests of society in any shape or form, regardless of whether it leads to profit.
  • Requires that both executives and employees must strive for social justice and must win the trust of customers, the market, and society, and takes the position that any anti-social, unjust interference is unacceptable and must be avoided.

Thus, our company has established a reporting station in the Human Resources and General Affairs department in the corporate planning division, and the Dunlop Sports Co. Ltd. Compliance Manual clearly stipulates that inappropriate interference in civic affairs is not to be condoned and action clearly not in the best interests of society are to be scrupulously avoided. Specific methods for dealing with the issue at all levels of management are listed in the Society Compatibility Manual and are well known to staff at all levels in all affiliated companies. In addition, should notification of illicit activities come from the corporate planning division, a system is in place so that the relevant divisions, departments, or companies can consider appropriate action, and the company as a whole can take action in accordance with the best interests of society.

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