P.46 Compliance

Compliance Business Foundation

Compliance-related policies and systems

Policies applicable to the Group

We have established the TBS Group Code of Conduct, which constitutes our highest-policy on how we should act toward customers, society, and the people we work with. More de- tailed behavioral requirements are set out in the TBS Group Standards of Conduct, which all Group employees are obligat- ed to observe. TBS Group Code of Conduct and Standards of Conduct https://www.tbsholdings.co.jp/about/governance/statement.html Furthermore, regarding respect for human rights and the prohibition of bribery and corruption, which are stipulated as imperatives in the Code of Conduct and Standards of Conduct and which we regard as particularly critical for the sustainabil- ity of both society and our company, we have formulated the TBS Group Human Rights Policy and the TBS Group Anti-Bribery and Corruption Policy. TBS Group Human Rights Policy https://www.tbsholdings.co.jp/sustainability/pdf/humanrights.pdf TBS Group Anti-Bribery and Corruption Policy https://www.tbsholdings.co.jp/sustainability/pdf/anti-bribery.pdf For our supply chain, we have established the TBS Group Sustainable Procurement Guidelines, which present requirements that should be observed in order to build good long-term relationships and contribute to the realization of a sustainable society. Going forward, we will seek to disseminate and promote understanding of these guidelines throughout the entire supply chain. TBS Group Sustainable Procurement Guidelines https://www.tbsholdings.co.jp/sustainability/pdf/sustainableprocurement.pdf In addition, we operate three different businesses—Media and Content, Lifestyle, and Real Estate and others—and build relationships with a diverse range of customers. Therefore, in order for Group employees and related parties to work safely and with peace of mind, we carefully considered how to respond when customers engage in conduct that exceeds the bounds of social acceptability, which led to the formulation of the TBS Group Basic Policy on Customer Harassment. TBS Group Basic Policy on Customer Harassment https://www.tbsholdings.co.jp/sustainability/pdf/customerharassment.pdf These compliance-related policies are being communicat- ed internally during training for new graduates, mid-career hires, and personnel newly promoted to managerial positions. As they are incorporated into mandatory training at career milestones, all employees receive the relevant training on a regular basis. Regarding customer harassment, in addition to the basic policy, we have produced response manuals and handbooks that provide more concrete guidance, and these are used to provide training specific to the characteristics of the customers faced by each internal department.

Internal reporting systems and response to individual cases

We have established internal and external reporting channels called the TBS Hotline, which allow not only our employees and staff, but also partners working with us, to report any miscon - duct. Reports to the internal hotline are received by personnel from the Legal & Compliance Division, while those to the external hotline are received by an outside law firm. We have also established a dedicated internal hotline for consultations regarding harassment. In addition, since 2024, we have been accepting complaints and consultations related to human rights through the grievance reporting channel operated by the Japan Center for Engage- ment and Remedy on Business and Human Rights (JaCER). Whistleblower TBS Hotline external reporting channel Law firm TBS Hotline internal reporting channel Legal & Compliance Division Human rights grievance reporting channel Investigation and corrective action review Feedback to whistleblower Reports are handled on a case-by-case basis, with the outside lawyers and the Legal & Compliance Division either col- laborating or responding independently. We also ensure that no disadvantage or retaliation occurs against those who make a report, and whistleblower confidentiality is strictly main- tained. Finally, we rigorously implement recurrence prevention measures targeting the relevant parties and departments, and if there are any individuals who have suffered harm, we make every effort to provide remedy. 46