LY Corporation Group Code of Conduct for Business Partner

1. Introduction
The LY Corporation Group Code of Conduct (hereinafter "Code of Conduct") is the code of conduct for all officers and employees (hereinafter collectively referred to as “Officers and Employees”) of LY Corporation and its Group companies (hereinafter collectively referred to as the "LY Corporation Group") .

2. Purpose of the Code of Conduct
In order to faithfully carry out the Mission of the LY Corporation Group, each and every one of us (all Officers and Employees of the LY Corporation Group) will comply with the Code of Conduct and maintain proper corporate governance. By doing so, we aim to earn the trust of our stakeholders — including our customers, shareholders, investors, business partners, local communities, and Officers and Employees — and fulfill our corporate social responsibilities, thereby enhancing our corporate value. We also ask our business partners to respect the content of this Code of Conduct. 

3. Commitment to compliance and ethical conduct
We not only comply with all laws and regulations, but engage in ethical behavior that upholds the trust of society.

4. Respect for basic human rights
4.1 We respect the rights of individuals and do not tolerate discrimination or disadvantageous treatment on the basis of difference in political beliefs, ideology, religion, gender, gender identity, sexual orientation, physical characteristics, disease, age, nationality, race, ethnicity, and so forth.

4.2 We understand and respect the culture and customs of the countries and regions in which we operate, and act accordingly.

4.3 We prohibit all forms of forced labor and child labor.

5. Ensuring a safe, healthy and harassment-free work environment
5.1 We do not tolerate sexual harassment, abuse of authority, or any other form of workplace harassment.

5.2 We comply with laws and regulations concerning occupational safety and health, while also taking into consideration the physical and mental health of Officers and Employees, and strive to ensure a safe and healthy work environment.

6. Respect for personal information and privacy
6.1 We acquire personal information in the course of business in an appropriate manner in accordance with the applicable laws and regulations in each market, and with a Privacy Policy in place.

6.2 We use the personal information acquired in the course of business within the scope specified in our Privacy Policy, and appropriately protect, manage, and dispose of such information. We do not provide such information to any third parties, except when we have obtained consent or when permitted by applicable laws.

7. Fair business practices
7.1 We comply with the business competition laws of each market where we operate, conducting our business activities with a spirit of fair play and on the principles of free and fair competition, and do not impose unfair trading conditions on our business partners or service users.

7.2 We do not obtain or allow others to bring in information about our competitors in an unfair manner.

7.3 To provide safe and secure services to our customers, we maintain fairness and integrity toward our customers and do not make misleading representations or engage in misleading conduct.

7.4 We comply with laws and regulations regarding imports and exports and other international trading rules.

7.5 We do not engage in prohibited transactions with specified countries, regions, organizations, or individuals that are subject to economic sanctions.

8. Avoidance of conflict of interest
We act with respect for the interests of the company and do not use our position or status in the company to prioritize the benefit of ourselves or that of a third party.

9. Appropriate use and management of company assets
9.1 We use, manage, and dispose of company assets and trade secrets appropriately, and do not use them for any purposes other than business. 

9.2 We recognize that intellectual property rights are important assets for the business activities of the LY Corporation Group, and appropriately protect the intellectual property rights of the LY Corporation Group and respect the intellectual property rights of third parties.

10. Thorough implementation of information security
We strictly protect and manage our information assets, including personal information and confidential information, and do our utmost to protect them from unauthorized access, leakage, falsification, destruction, or the like.

11. Accurate, fair, timely, and appropriate information disclosure
11.1 We create accurate and complete accounting records.

11.2 We disclose accurate information to society and the stock market in a fair, timely, and appropriate manner.

11.3 We strictly manage insider information and do not engage in insider trading.

12. Maintenance of political neutrality
We maintain political neutrality, not favoring or supporting any specific group or individual.

13. Prevention of bribery and corruption
13.1 We do not engage in any form of bribery, corruption, or corrupt practices, whether with public servants or private citizens.

13.2 In order to ensure fair trade, we provide and accept business entertainment and gifts only to the extent deemed appropriate.

14. Rejection of relationships with crime
We reject any involvement with anti-social forces including Boryokudan (organized crime syndicates) and other organized criminals, as well as criminal activities such as money laundering and terrorist financing.

15. Social contribution and environmental protection
We actively contribute to society and protect the environment through our business activities, taking into consideration the social and environmental impact of our business activities, and aim to build a sustainable society. We encourage our Officers and Employees to take an interest in, actively participate in, and support these activities.

16. Consultation and whistleblowing on compliance issues, and prohibition of retaliation
16.1 If we discover any improper acts or suspected compliance violations, we consult with or report them to our supervisor, the compliance consultation desk, or the whistleblowing hotline.

16.2 We prohibit any retaliation or disadvantageous treatment towards whistleblowers regarding compliance.

17. Revision and abolition
The revision or abolition of this Code of Conduct shall be drafted by the division in charge of compliance and approved by the Board of Directors of LY Corporation.

Established on April 23, 2021
Revised on October 1, 2023

*Unless otherwise specified, English-language documents are prepared solely for the convenience of non-Japanese speakers. If there is any inconsistency between the English-language documents and the Japanese-language documents, the Japanese-language documents will prevail.