Introduction The Little Cat Co., Ltd. (hereinafter referred to as the "Company") shall apply mutatis mutandis to The Little Cat Co., Ltd.‘s business conduct rules and code of ethics, and shall be a guide in making decisions on ethics. The Company is committed to thorough integrity in everything the Company does, internal relationships, and relationships with people outside the Company. While the standards of this Regulation are primarily based on laws that apply to all of us, in some cases beyond legal obligations. In this regard, this Regulation sets out the principles that we must adhere to in order to avoid situations that violate the values sought by the Company or may appear to be so. Chapter 1: general rules Article 1 [Purpose] The purpose of these Rules is to set forth the principles that we must follow in order to avoid situations that violate, or may appear to violate, the values of the Company. Article 2 [Scope of Application] These Regulations apply to the Company (including domestic and foreign investment companies with management rights) and its employees, and the Company's business partners are encouraged to understand and implement these Regulations. Article 3 [Definition of Terms] The definitions of terms used in these Regulations are as follows. Socially Acceptable Refers to a level that should be acceptable to most people with sound common sense and does not interfere with the fair conduct of business. Stakeholder Any party with an interest in the Company, including competitors, customers and suppliers, and shareholders. In a broad sense, it includes consumers, employees, communities, the media, and civil society organizations. Tangible and intangible assets Includes Company funds in any form, as well as machinery, supplies, tools, inventory, funds, computer systems and equipment, computer software, computer data, vehicles, records or reports, confidential information, intellectual property or other sensitive information or materials, and communications by telephone, voicemail or e-mail. Business Partner ("BP") Refers to companies/organizations and individuals who have or wish to have a trade or business relationship with the Company, even if they have a personal relationship (friends, relatives, etc.). Public Officials, etc. "Refers to a public official or a person engaged in public business as defined in the Act on the Prohibition of Corruption and Graft, and a person who is prohibited from engaging in corruption and graft as defined in the Act. Ethics Department Refers to the department in charge of the company's ethics management, including the management of the ethics regulations. Chapter 2: Attitude of Members Article 4 [Sincere Performance of Duties] All executives and employees shall clearly recognize their authority and responsibilities and perform their duties in good faith based on the principles of honesty and trust. In particular, they shall not perform tasks unrelated to the company's business or engage in solicitation activities during working hours. Article 5 [Offices and Adjunct Positions] All employees and members of the Board of Directors of the Company shall not work for or receive remuneration for services from other competitors, customers, distributors, or suppliers without the approval of the Ethics Department. Employees must obtain approval from the Board of Directors when they wish to serve on the board of directors of a government agency or another company. In particular, members of the Board of Directors must obtain approval by a majority vote of the Board of Directors when they perform any of the following acts. ① As a director or limited liability partner of another company engaged in the same business as the Company. Entering into a transaction in the Company's business area in the name of a director or a third party. Entering into a transaction with the Company in the name of the director or a third party. Even when authorized by the Board of Directors pursuant to Paragraph 2, employees and members of the Board of Directors must take appropriate measures to distinguish between company business and non-company business. The Ethics Department may conduct audits of the "appropriate measures" referred to in Paragraph 3 if necessary and request correction of any inappropriate matters. Article 6 [Maintaining Decency] All executives and employees shall keep in mind that their behavior directly affects the trust and reputation of the Company and shall endeavor to fulfill their responsibilities and duties as members of society. Article 7 [Protection of Company's Assets and Information] All employees shall appropriately allocate and use the Company's tangible and intangible assets. Employees shall protect the Company's assets from loss, damage, misuse, theft, or destruction due to negligence. Employees shall ensure that the Company's assets are used effectively. Company assets must be used only for business purposes. Any use of Company assets or services not for the benefit of the Company requires management approval. The Company and its employees shall keep accurate books and records In accordance with applicable laws, the Company shall ensure that its books and records accurately and fairly reflect the transactions and dispositions of the Company's assets in a reasonably detailed manner. In particular, the requirements of the following items shall be strictly respected. False and misleading entries are strictly prohibited, and the Company shall not tolerate undisclosed debts or assets for any purpose. Payments shall be made only for the purposes recorded in the supporting documents. All employees shall implement management and accounting controls to ensure the accuracy and fairness of financial statements and other reports. All employees shall cooperate fully with the Company's internal and external auditors. All employees shall protect and manage the Company's information and trade secrets and comply with the Company's security standards. This obligation is valid even after leaving the Company, and in particular, the following acts are strictly prohibited. ① (Unauthorized access to user information) Accessing user information without authorization. ② (External leakage) Leaking the Company's internal information to the outside world. - Leaking to media organizations - Leaking to external channels used by many people, such as blogs, blinds, etc. - Leaking to external acquaintances such as family, friends, and former colleagues. ③ (Internal leakage) Leaking the company's internal security information acquired in the course of business to unauthorized persons within the company. ④ (Insider information trading) Trading in the company's shares using insider information. Article 8 [Creating a Sound Corporate Culture] All executives and employees shall not engage in any act that hinders the formation of a healthy relationship between superiors, subordinates, and colleagues, such as sexual harassment or forcing them to perform acts that impose personal burdens, and shall create a healthy organizational atmosphere by recognizing them as mutual partners and respecting them personally. In particular, the following acts are strictly prohibited for the purpose of creating a healthy corporate culture. (Assault) Physical violence (including threatening behavior) (Verbal abuse) Verbal abuse (Sexual harassment) causing another person to feel sexually humiliated (Discrimination) Discriminatory comments or behavior that demeans others. (Concealment) Telling or writing falsehoods to conceal the truth from coworkers within the company. Article 9 [Fair Business Conduct] All executives and employees must strictly distinguish between business and personal affairs when dealing with BP and perform their duties fairly and transparently. All employees must give BP and its business partners a fair chance to do business, and must not use their superior position to make demands or statements that undermine fair trade. All executives and employees shall not exert personal influence on the process of managing, supervising, or reviewing the work evaluation or salary of themselves and their close relatives. Article 10 [Conflict of Interest] All executives and employees shall not engage in any conflict of interest or form a conflict of interest relationship in connection with the Company's legitimate business endeavors. The following acts are prohibited if it is believed that an employee can exercise business influence or can influence the employee's judgment or behavior in the performance of business. However, the following is not an exhaustive list of conflicts of interest, so strict judgment and application are required in actual situations. (1) Employees engage in business with the Company, BP, or a competitor, either directly or through a third party. Entering into a loan, co-investment, loan guarantee or lease of real or personal property with BP, either directly or through a third party. Receiving compensation from BP, either directly or through a third party. ④ Holding shares or bonds of BP directly or through a third party (except with the approval of the Company). The following activities are prohibited, in which an employee uses business information acquired in the course of performing his/her duties to make unfair profits directly or through a third party. (1) Directly or through a third party, an employee purchases property or securities that the company intends to purchase or lease. (2) Receiving employment or job referrals from BP for oneself or a third party on the basis of private advice or other opportunities using company information. Employees must report to the Ethics Department if their family members and relatives have business dealings with the Company or BP, as this may create a conflict of interest. Article 11 [Money and Entertainment] All executives and employees shall not accept any money, entertainment, hospitality, etc. from other parties, including stakeholders, and if unavoidably accepted, shall take the following measures and report to their supervisor and report the progress to the Ethics Department. (1) If it is possible to return it, it must be returned immediately. If it is impossible or difficult to return it, contact the Ethics Department and handle it according to the guidance of the Ethics Department. In the following cases, the acceptance of money, entertainment, and hospitality is exceptionally authorized. However, the amount or value must be within the range that is acceptable according to social norms. If you have any difficulty in determining this, you should contact the Ethics Department. Publicity and event souvenirs Condolence money Modest food and beverages All executives and employees shall not provide any money, entertainment, or hospitality to other parties, including stakeholders. In particular, they shall not provide illegal solicitations, money, entertainment, or hospitality to public officials in violation of the Act on the Prohibition of Illegal Solicitation and Receipt of Money, etc. All executives and employees shall not request any gifts, honorariums, other rewards, or business preferences from stakeholders for the benefit of their family members or friends. If you attend meetings organized by governments and government agencies on behalf of the company and receive a meeting fee, you must report the meeting fee to the Ethics Office. In principle, employees shall report in advance to the head of the organization any contact with BP, etc. outside of business hours in connection with their work. Article 12 [Compliance with the Code of Ethics] All executives and employees are obligated to comply with this Code and pledge to comply with it, and if they have any doubts regarding its interpretation and application, they must consult with and receive advice from the head of the Ethics Department. All executives and employees shall report any cases of violation of this Code of Ethics to the Ethics Department. Each organization head is responsible for actively supporting and managing their employees and BPs with whom they work to ensure that they understand and comply with the Company's Code of Ethics. All employees are required to sign an annual pledge to practice ethical management and to comply with the pledge. In case of violation of this regulation, measures will be taken in accordance with the company regulations. Chapter 3: Responsibility to Customers Article 13 [Customer-centered management] In the process of developing products, the Company shall provide products and services that satisfy customers by introducing pre-verification procedures to enhance product completeness. The Company shall make every effort to accurately identify customer requirements, actively accept customers' legitimate demands and reasonable suggestions, and keep its promises to customers. The Company shall provide accurate information in a timely manner so that customers can reasonably select products and services. Article 14 [Protection of Customer Information] The Company shall comply with customer information protection laws and regulations, continuously check and improve business processes to protect customer information, and, if necessary, introduce and operate a customer information pre-impact assessment system at the product development stage. The Company shall make its best efforts to protect customer information, including the operation of optimal IT security systems and specialized customer information managers. The Company shall not use customer information for purposes other than those for which it was provided or provide it to third parties, except with the consent of the customer or as permitted by law. Article 15 [Enhancement of Customer Value] In providing products and services to customers, the Company shall do its best to improve customer value, including maintaining the quality level expected by customers and creating a safe and beneficial use environment. Chapter 4: Responsibilities to Employees Article 16 [Human-centered Management] The Company provides a work environment that does not discriminate on the basis of race, ethnicity, gender, belief, religion, age, disability, or sexual preference. The Company respects the humanity of its employees and treats them fairly and reasonably based on their capabilities and performance. The Company supports the achievement of each employee's goals, including the organization of an optimal work environment. The Company supports the self-development activities of all employees and actively provides learning opportunities necessary for job performance. Article 17 [Safety and Happiness of Employees] The Company shall comply with international standards, relevant laws and regulations, and internal regulations in this regard by establishing a system for the safety and health of all employees and regularly conducting related training. The Company shall do its best to ensure that all executives and employees have mutual trust and pride, express their challenging spirit and creativity, and pursue happiness with their colleagues. Chapter 5: Responsibility to Shareholders Article 18 [Enhancement of Corporate Value] The Company maximizes corporate value through transparent and efficient management through continuous innovation, and shares the results with shareholders. Article 19 [Protection of Shareholders' Rights and Interests] The Company practices transparent management centered on the BOD and respects the legitimate requests and suggestions of shareholders. The Company shall prepare disclosure materials such as financial statements in accordance with all laws and accounting standards, and make adequate, accurate, complete, and timely disclosures in accordance with relevant laws and regulations. Chapter 6: Relationship with Business Partners Article 20 [Win-Win Management] The Company shall select BPs suitable for business purposes by applying fair and reasonable standards, evaluate the process and quality of their performance based on the same standards, and communicate them to the BPs in an appropriate manner. The Company shall not engage in unfair behavior using its superior position and shall pursue mutual benefits and common development. The Company recognizes BP as a strategic partner to pursue the common value of customer happiness based on mutual trust. Article 21 [Protection of BP Information] The Company shall protect BP's information and trade secrets and shall not use them for purposes other than those for which they were provided, except with BP's consent or as permitted by law. The Company shall not acquire or use information or trade secrets of other companies, including BP, in an illegal or unfair manner. Chapter 7: Responsibility to Society Article 22 [Compliance with laws, rules and regulations, etc.] The Company's policy is to be a good "corporate citizen," and all employees of the Company shall comply with the following laws, rules, and regulations. The laws and rules of the countries in which the Company operates Terms and conditions of business contracts Other customs and standards that are generally accepted as ethical in the region where the Company operates. Article 23 [Restriction of Competition] The Company shall comply with the laws restricting competition in the countries where the Company operates. The Company or any of its employees shall not engage in any collusive behavior, including entering into agreements with other parties that unreasonably restrict competition. Employees shall not discuss with competitors information sensitive to competition, such as pricing, contract terms, and other confidential information. Article 24 [Creating a Healthy Culture] The Company shall improve the quality of human life and contribute to the happiness of mankind by realizing a convenient and affluent world through continuous technological innovation and business sophistication. The Company shall endeavor to form and create a healthy culture in the local community when conducting business, including considering whether the services provided in the business area are socially and culturally harmful. Article 25 [Respect for Human Dignity] The Company shall not engage in unreasonable discrimination based on race, religion, gender, disability, etc. against all stakeholders such as customers and employees in the business area. The company protects basic human rights, such as the protection of minors and customer privacy in the business area. Article 26 [Environmentally Friendly Management] The Company shall comply with international standards related to environmental protection, related laws and regulations, and internal regulations, and practice environmentally friendly management. Article 27 [Social Contribution Activities] The Company shall actively participate in social service activities such as volunteering and disaster relief as a corporate citizen in the business area. Article 28 [Maintaining Political Neutrality] The company respects individual suffrage and political expression, but does not recognize any personal political activities that use company funds, manpower, facilities, etc. for political purposes. Any political contributions made by employees on behalf of the Company without the approval of the CEO are prohibited. The Company shall refrain from improper transactions with the government and comply with the relevant laws and regulations of each country. Chapter 8: Ethics Consultation, Reporting and Protection of Informants Article 29 [Ethics Consultation, Reporting and Protection of Informants] The ethics department may establish and operate a "hotline report" for ethics consultation in the company system. The head of the ethics department shall conduct additional fact checks on ethics management-related consultations and reports with the approval of the Standing Ethics Committee and take the following measures as necessary. (1) Depending on the matter consulted or reported, it will be delegated to the department in charge of the relevant work or handled by the head of the ethics department in consultation with the relevant department. If it is deemed necessary to conduct a disciplinary review, it may be proposed to the Standing Ethics Committee for review. The Company will take the following measures in the event of a BP-related consultation or report. ① Considering the gravity of the case, the degree of violation, etc., the Company may submit a memorandum on prevention of recurrence and determine the sentence of the BP and the counseled/reported person. Notwithstanding the provisions of the preceding paragraph, the Company may take necessary measures, such as limiting the volume of transactions with the BP or terminating the contract, in consideration of the gravity of the matter and the degree of impact on society and the Company. The Company shall make its best efforts to protect consultants and reporters and encourage consultation and reporting. The Company shall protect the identity of the consultant/reporters and the contents of the consultation/report, and shall make every effort to ensure that the consultant/reporters do not suffer any disadvantages due to the consultation/report. ② If a counselor/reporter believes that his/her identity has been exposed and it is necessary, he/she may notify the head of the ethics department and request identity protection, in which case the head of the ethics department may take necessary measures such as legal support and department transfer in consultation with the heads of the departments in charge of human resources management and legal management. ③ All executives and employees shall not engage in any act or retaliatory behavior that enables the identity to be exposed, such as inquiring about the identity of the counselor/reporter to the ethics department or conducting an investigation to find out the identity, and the attempted act alone may result in disciplinary review. ④ If the counselor-reporter has engaged in misconduct, but has consulted and reported the fact, the company may take into account mitigating circumstances when punishing or disciplining the misconduct. ⑤ The Company may reward a counselor/reporter who has contributed to the interests of the Company through counseling/reporting. The head of the ethics department shall record and keep the details of consultations and reports related to the Code of Ethics and the results of processing in order of the date of receipt. Additional rules Article 1 [Effective Date] This regulation shall take effect from September 6, 2018. Code of Business Ethics - Revised on September 6, 2018