Seibu Group Code of Corporate Ethics

All of us at the Seibu Group fulfill our social responsibilities as a corporate group carrying out business activities with a strong public spirit rooted in all aspects of our customers’ daily lives and local communities, and we aim to be a corporate group trusted by our local communities and society at large. To that end, we have established the Seibu Group Code of Corporate Ethics as presented below, which is to be followed by all our officers and employees.

1. Focus on customers

To meet the expectations of our customers, we sincerely acknowledge customers’ needs and provide quality services and pleasant times and spaces for our customers, while always giving top priority to safety and peace-of-mind.

2. Compliance

We comply with all laws and regulations and internal regulations, and behave in a fair and sincere manner with social good sense. Moreover, we take a firm stand against antisocial forces and organizations that threaten the order and safety of civil society.

3. Respect for human rights

Every officer and employee shows respect for the character and individuality of other officers and employees, and takes sincere action to create a workplace with an open atmosphere conducive to being able to work with peace of mind.

4. Obligation as a corporate citizen

As a company, we are conscious of being a member of society. We strive to communicate broadly with society, and disclose corporate information in a timely and appropriate manner. We strive to be careful of the environment in our business activities and help develop the local communities and society at large.

5. Conduct of executives

The Group officers and executive employees take initiative and strive to realize the spirit of this code. If circumstances arise that go against the contents of this code, the top management in person will strive to solve the problem by identifying the cause of the problem and establishing preventive measures as well as clarifying where responsibilities lie.

Seibu Group Principles of Conduct

1-1. Put safety first

We give top priority to the safety and peace-of-mind of our customers.

1-2. Respond with sincerity

We respond with sincerity and fairness while always considering our customers’ standpoint.

1-3. Provide quality services

We always carefully listen to what our customers tell us and are determined to meet new challenges to offer high quality services in anticipation of the coming times.

1-4. Safeguard customer information

We take meticulous care in managing our customers’ personal information.

2-1. Comply with laws and regulations and internal regulations

We understand the spirit of laws and regulations, official notices, internal regulations, etc. and carry out business appropriately in compliance with them.

2-2. Ensure appropriate reporting and record taking

We take steps to ensure appropriate and factual reporting and record taking.

2-3. Stand against antisocial forces

We take a firm stand against antisocial forces and organizations and a zero-tolerance policy toward any conduct that facilitates the activities of such forces.

2-4. Conduct fair trading

We never conduct inappropriate transactions that obstruct free and fair competition.

2-5. Don’t accept or provide excessive gifts and entertainment

We never accept nor provide gifts and entertainment outside the scope of what is generally accepted in society.

2-6. Relations with politicians and bureaucrats

We maintain appropriateness in our relations with politicians or people in public office and never engage in conduct that invites distrust from society.

2-7. Use company assets appropriately

We handle company assets appropriately and never use them for nonbusiness purposes.

2-8. Properly manage confidential information

We recognize the importance of confidential information and take measures to ensure its proper management.

2-9. Prohibit insider trading

We do not conduct insider trading that uses the internal information of companies we learn of through business, any company of the Seibu Group, or any business trading partner.

2-10. Safeguard personal information

We take proper measures when obtaining and using the personal information of our business trading partners and other related parties. We always keep such information safely managed and never engage in conduct that would infringe the privacy or personal information.

2-11. Safeguard intellectual property rights

We protect the Company’s intellectual property rights and never engage in conduct that would breach the intellectual property rights of a third party.

2-12. Safeguard peoples’ rights of image

We protect peoples’ rights of image and never engage in conduct that would infringe the image rights of a third party.

3-1. Don’t engage in discriminatory behavior

We mutually respect each other’s character and individuality and never engage in conduct that would be construed as discrimination or harassment. We never tolerate such behavior.

3-2. Comply with labor-related laws and regulations

We comply with labor-related laws and regulations and strive to create safe and worker-friendly environments.

3-3. Promote communication

We act with sincerity while being considerate of the feelings of others and work to build relationships of mutual trust.

4-1. Disclose information

We carry out disclosure of corporate information to society, particularly to shareholders and investors, in a timely and appropriate manner, and we do not try to cover up negative information.

4-2. Take action on environmental problems

We aim to create earth-friendly environments, and we actively tackle environmental issues.

4-3. Contribute to development of the related countries and regions

We respect the cultures and customs of each country and region, and strive to help develop their economy and society through our business activities.