CODE OF ETHICS AND CONFIDENTIAL REPORTING POLICY

The Holding Company is committed to the highest standards of integrity, and ethical and legal conduct in dealings with its stakeholders. The Code of Ethics and Confidential Reporting Policy, which outlines the ethical and professional management practices that PSS Holdings Co., Ltd. upholds, have been adopted by the Board.

The principles of business conduct are not only expected to be followed at the management level, but throughout PSS's business network. As well as being available on this website, the principles are disseminated to all employees in all regions who are expected to follow these principles as a part of their employment duties. In addition, given our commitment to these principles, we also expect that those doing business with us will deal in the same way we are committed in dealing with them.

Business principles detailing the holding company's approach to community and social development issues and its labor practices have also been formulated on a group-wide basis. In addition, a policy providing for the confidential reporting by employees of acts of fraud, dishonesty, and other actions of unethical and illegal nature, including acts that offend PSS's Code of Ethics, by other employees or those with whom they are doing business, was finalized. The procedures and mechanisms for such a reporting permit are confidential reporting via facsimile and anonymous email. Once a report is made, this will be investigated and appropriate action will be taken. Information on the reporting mechanisms and the policy on such reporting are communicated to all employees by means of a roll-out campaign at regional levels and through the company intranet.

As the holding company's Code of Ethics and Confidential Reporting Policy have been newly introduced, it is still early to gauge the extent to which there is adherence to these ethical standards. The findings of the internal and external audit functions to date have revealed no significant breaches of these standards. Through the widespread dissemination of these standards and the emphasis of these standards in employee training, the company is confident of a high level of adherence to its ethical standards.