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Basic Policy on Corporate Governance

SUNNY SIDE UP GROUP Inc. regards “PR (Public Relations) thinking,” which aims to foster mutual understanding and consensus between companies and society, as one of its management strategies that permeates the entire group’s business. In order to understand and prepare for what the entire society, including diverse stakeholders, expects from companies, it is essential to strengthen corporate governance. We believe that promoting the soundness and efficiency of management through these efforts will lead to the improvement of corporate value. SUNNY SIDE UP GROUP also adopts a group management system based on the “separation of management supervision and execution,” with the Board of Directors responsible for supervising management and making decisions regarding the group management system.

Management Structure

SUNNY SIDE UP GROUP is a company with a Board of Directors, and the Board of Directors makes decisions on matters stipulated by laws and regulations and the Articles of Incorporation, as well as other matters related to the execution of our business. In principle, we hold regular meetings of the Board of Directors once a month, and in the event of urgent agenda items, we promptly convene extraordinary meetings of the Board of Directors, thereby establishing a system that enables swift management decisions.

Basic Policy on Compliance

We, SUNNY SIDE UP GROUP, believe that it is essential to comply with laws and internal rules, respect social norms, and conduct corporate activities in a sincere and fair manner in accordance with social ethics. We have established these guidelines for compliance activities, and each and every employee promises to have a high sense of ethics and take responsible actions as members of society.

[Code of Conduct]

● Customer Satisfaction
We always put our customers first, respond to their needs and trust, and provide safe and excellent products and services.
● Fair Trade
We are committed to fairness and transparency based on laws and social ethics, and maintain appropriate relationships with business partners, politics, and administration.
● Development of Human Resources and Pursuit of Diversity
We maintain a comfortable and easy-to-work workplace free of discrimination and harassment, and realize the development and fair and appropriate utilization of human resources.
● Information Protection
We properly manage and operate information from customers and business partners, as well as employees’ personal information.
● Respect for Intellectual Property Rights
We respect intellectual property rights, make effective use of our own rights, and properly manage them so as not to infringe on the rights of others.
● Management of Company Assets
We use, manage, and operate company assets in accordance with appropriate rules.
● Environmental Conservation
We recognize the importance of environmental issues and strive to conserve the environment.
● Severance of Ties with Anti-Social Forces
We have absolutely no relationship with anti-social forces.

SUNNY SIDE UP GROUP Inc.

Human Rights Policy

SUNNY SIDE UP GROUP Inc. and its consolidated subsidiaries (hereinafter referred to as “the Group”) believe in the power of PR (Public Relations), which states that “if people’s hearts are moved, their actions will change, and eventually the world will change.” Through communication-related business activities, we aim to solve various issues and create new values for a new era in the world. The Group believes that communication services created by each individual, who is responsible for “fun commotion,” with their human rights, diverse personalities, and values respected, and with their abilities fully demonstrated, will lead to a better world. To this end, the Group has formulated this Human Rights Policy (hereinafter referred to as “this Policy”) and will promote continuous efforts to respect human rights.

[Important Issues Related to Human Rights]

● Respect for Diversity and Prohibition of Discrimination
We mutually recognize diverse personalities and values, and prohibit discrimination and human rights violations based on race, nationality, religion, age, gender, sexual orientation, gender identity, disability, etc.
● Prevention of Harassment
We always keep in mind to prevent all forms of harassment and strive not to harm the honor or dignity of individuals.
● Development of a Workplace Environment Where Everyone Can Thrive
We provide equal opportunities to each individual, regardless of nationality, age, gender, or other attributes, so that they can be themselves and thrive. We also properly manage working hours and develop a safe and healthy workplace environment so that they can fully demonstrate their abilities.
● Respect for Human Rights in Provided Services
We will establish a checking system and pay maximum attention to ensure that the expressions in the communication services provided by the Group do not lead to human rights violations.

1. Scope of Application of the Human Rights Policy

This Policy applies to all officers and employees (officers, regular employees, contract employees, and part-time employees) and dispatched employees of the Group. We also expect that related parties, including the Group’s business partners, will cooperate in respecting human rights in accordance with this Policy.

2. Compliance with International Norms and Laws

The Group complies with international norms such as the human rights stipulated in the “International Bill of Human Rights,” the principles regarding fundamental rights listed in the “ILO Declaration on Fundamental Principles and Rights at Work,” and the “Children’s Rights and Business Principles” formulated by UNICEF, the United Nations Global Compact, and Save the Children. We also comply with the laws and regulations applicable in the countries and regions where we conduct business activities. If there is a conflict between internationally recognized human rights and the laws and regulations of each country or region, we will pursue methods to maximize respect for international human rights norms.

3. Governance on Human Rights

The Board of Directors of SUNNY SIDE UP GROUP supervises the efforts to respect human rights stipulated in this Policy. The Board of Directors receives regular reports on human rights infringement risks from the Risk and Compliance Committee, discusses important issues related to human rights, and supervises the impact on business activities.

4. Correction and Remedy

If it becomes clear that the Group’s business activities have caused or promoted negative impacts on human rights, we will work to correct them through appropriate means. We will verify the contents of consultations and reports received regarding human rights, and if human rights violations are confirmed, we will take corrective measures.

August 1, 2024
SUNNY SIDE UP GROUP Inc.
President and CEO Etsuko Tsugihara

Environmental Policy

SUNNY SIDE UP GROUP recognizes that the preservation of the global environment and the prevention of pollution are important management issues through its business activities, and formulates this environmental policy in order to aim for harmony between business activities and the global environment.
Based on the following code of conduct, we will set and review environmental objectives and targets after recognizing the environmental impact caused by business activities.
In addition, all employees and business partners will actively work on environmental issues and continuously improve.

[Code of Conduct]

  1. In business activities, we will strive for energy-saving activities in order to prevent pollution and reduce environmental impact.
  2. We will comply with laws and regulations related to environmental protection and other requirements that we have agreed to.
  3. We will thoroughly disseminate, implement, and maintain environmental management so that all employees and business partners can improve their awareness of environmental protection and understand the environmental policy.
  4. In order to achieve this environmental policy, we will set environmental objectives and targets and strive to promote environmental activities toward their achievement.
SUNNY SIDE UP GROUP Inc.
President and CEO Etsuko Tsugihara
For our Group’s greenhouse gas emissions, please see here.
　
Greenhouse gas emissions (FY ending June 2024 to FY ending June 2026)

Basic Information Security Policy

[Basic Stance]

Information assets are the most important assets for SUNNY SIDE UP GROUP. In order to reliably protect the information assets managed by SUNNY SIDE UP GROUP from the threats surrounding them, it is necessary to establish sufficient and well-balanced information security management measures. Information assets can further increase their value through preservation and sharing, and are essential for the continuation, maintenance, and development of business. By proactively constructing, introducing, operating, monitoring, reviewing, maintaining, and improving information security management measures, the sense of solidarity within the company organization will be strengthened, and strong trust can be received externally by complying with laws and regulations surrounding companies, including the Personal Information Protection Law. The purpose is to further enhance the overall strength of SUNNY SIDE UP GROUP externally by continuing to manage information security.

  1. By implementing information security measures, we will further enhance customers’ peace of mind and trust in our company.
  2. We will also strive to raise awareness and understanding of our basic policies and stances among our partner companies, and work together to improve information security.
  3. Educational activities, training, and briefings will be provided to all employees and SUNNY SIDE UP GROUP’s partner companies to improve information security.

[Code of Conduct]

  1. In daily operations, each employee clearly evaluates and understands the importance of the information asset value of information assets entrusted to SUNNY SIDE UP GROUP by customers, the high risk value of the situation in which the company and business operations would be hindered or damaged if they were lost or leaked, and implements information security safety management measures that can clearly identify the undisclosed information assets. At the same time, SUNNY SIDE UP GROUP’s information security safety management measures will be implemented for SUNNY SIDE UP GROUP’s partner companies, and they will work together on operations.
  2. If any improvements are required in daily operations, business management regulations describing the countermeasures and rules will be created and implemented.
  3. Furthermore, education and awareness activities will be conducted regularly and at any time to ensure that employees and partner companies comply with information security and related laws, regulations, and contractual matters surrounding the advertising industry.

December 1, 2007
SUNNY SIDE UP GROUP Inc.
President and CEO Etsuko Tsugihara

Declaration to Exclude Anti-Social Forces

SUNNY SIDE UP GROUP Inc. and its subsidiaries (hereinafter referred to as “the Group”) declare that they will exclude any group or individual that pursues economic benefits by making full use of violence, force, and fraudulent methods, such as organized crime groups, members of organized crime groups, quasi-members, companies affiliated with organized crime groups, corporate racketeers, groups claiming to be engaged in social movements, and special intellectual crime groups (hereinafter referred to as “anti-social forces”), with the following items as basic policies.

  1. The Group will respond to unjust demands from anti-social forces as an entire organization.
  2. The Group will ensure the safety of employees who respond to anti-social forces.
  3. The Group will sever all relationships with anti-social forces, including the provision of services and other business relationships.
  4. Even if unjust demands from anti-social forces are based on scandals in business activities or employee misconduct, the Group will respond in a transparent manner and will never engage in backroom deals to conceal the facts.
  5. The Group will build close cooperation with external specialized organizations such as the police, violence eradication promotion centers, and lawyers, and will work to eliminate anti-social forces.
  6. The Group will take legal action against unjust demands from anti-social forces from both civil and criminal perspectives.
  7. The Group will resolutely reject unjust demands from anti-social forces.