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Compliance

Compliance Policy

The Timee Group sets forth the vision of "Helping individuals create more valuable time" and the mission of "Building infrastructure for expanding life’s possibilities through work." To fulfill our responsibilities as a company supporting social infrastructure, we position strict adherence to compliance standards grounded in high ethical standards—going beyond mere legal compliance—as a key management issue.

At its core, this policy reflects our commitment to sincerely honoring the trust placed in us by our service users, client companies, and society as a whole by continuously operating our business in a transparent and fair manner. Furthermore, our strongest foundation for protecting the integrity of our services lies in each employee embodying our values and upholding ethical standards.

We strictly prohibit and do not tolerate any misconduct that could lead to legal violations or a loss of social trust. We will cultivate a sound and open organizational culture that enables all officers and employees to consistently base their actions on high ethical standards.

This policy outlines the Timee Group's fundamental approach to compliance, and the Board of Directors has approved it.

Fair Trade and Anti-Bribery and Corruption

Prohibition of Bribery and Corruption

We prohibit offering, promising, or providing money or benefits to any business partners, including politicians and public officials, for the purpose of obtaining business advantages or inducing improper official acts. Additionally, we do not tolerate bribery, wherein we demand or receive benefits in exchange for providing improper advantages.

Fair Transactions and Proper Hospitality

We restrict business entertainment and gifts to within the bounds of social norms and the law, and we strictly enforce transparency to prevent any outward appearance of suspicion or distrust. Furthermore, we execute only those transactions that guarantee fair and reasonable compensation and content.

Prohibition of Political Contributions

We maintain political neutrality and do not support any specific political party or politician. We do not make political contributions to promote positions or policies favorable to our Group.

Fair Charitable Contributions or Sponsorship

When we make charitable contributions or sponsorships, we do so free from any involvement in corrupt practices.

Proper Information Management

Management of Confidential Information

We protect the personal information and privacy of service users and employees, as well as the confidential information of our client companies. We implement preventive measures to protect this information from unauthorized access and illicit disclosure.

Identification and Management of Conflicts of Interest

We do not allow the personal interests of officers and employees to influence business decision-making. If external activities conflict with, or are suspected to conflict with, their responsibilities as officers or employees of our Group, we appropriately identify and evaluate the situation and take necessary measures to ensure we do not harm the company's interests.

Management of Insider Information

We manage insider information by prohibiting the communication of facts that may constitute undisclosed material information to third parties, as well as the recommendation to buy or sell specific securities. We prevent insider trading before it occurs, stipulate the social and ethical responsibilities of our officers and employees, and secure the trust of our Group.

Human Rights, Environment, and Workplace Environment

Respect for Human Rights and Non-discrimination

We respect individuals’ human rights and do not engage in any conduct that promotes unjust discrimination.

Ensuring a Supportive Workplace Environment

We eliminate human rights violations such as discrimination, acts of violence, sexual harassment, and power harassment in the workplace.

Consideration for Environmental Protection

Recognizing that conserving the global environment is the foundation for the sustainable growth of our business, we conduct our activities with careful consideration for environmental protection.

Compliance System

Whistleblower Protection and Corrective Actions

We operate a whistleblowing mechanism and rigorously enforce whistleblower protections, ensuring the privacy of whistleblowers and strictly prohibiting any adverse treatment of them.

Internal Audits and Anti-corruption Measures

An independent internal audit office conducts regular audits across the ompany and all operations of our group companies to verify compliance with this policy. The office reports the audit results directly to the President and the Audit and Supervisory Board, and shares them to ensure management-level oversight. If we confirm any actions that violate this policy, we will immediately take corrective measures and implement strategies to prevent recurrence, addressing the violations strictly in accordance with our employment regulations and other internal rules.

Established in July 2026

Compliance Promotion System

To maintain a sound and highly transparent management infrastructure and to appropriately manage risks, the Timee Group has established the Risk and Compliance Committee as the oversight body in accordance with its Risk Management Regulations and Compliance Regulations. This Committee is chaired by the President, who holds ultimate responsibility for risk management and the execution of compliance, and consists of Executive Directors, Audit & Supervisory Board Members, and Executive Officers from various departments.

The Committee provides centralized oversight, ranging from the formulation of risk management policies, including compliance risks across the entire Group, to the monitoring of their operational status. Specifically, it operates a cycle of continuous improvement by designing a comprehensive program that incorporates an appropriate promotion system and infrastructure, and by conducting regular reviews.

In addition to holding regular meetings, this Committee convenes on an ad-hoc basis as necessary when serious incidents or risks are of concern, establishing an agile governance structure that enables a swift understanding of the situation and the implementation of appropriate corrective measures.

Establishment of Whistleblowing Mechanism

Timee, Inc. outlines the establishment of a whistleblowing contact point and the escalation process for incident reporting in its Internal Whistleblowing Regulations. The company has established an internal contact point handled by the Legal Department and Audit & Supervisory Board Members, available to all employees (including contract employees, dispatched workers, part-time employees, and those engaged under outsourcing or other contracts) as well as former employees.

The company ensures that employees are well informed about the whistleblowing mechanism and contact points through onboarding and compliance training, as well as  internal information-sharing tools. Separately from the whistleblowing contact point, the company has also established and operates a harassment consultation desk within the Human Resources Department.

Reception and Response

The personnel responsible for the contact point conduct fair and impartial investigations. The contact point personnel and the manager in charge investigate the reported matters, and if necessary, the company establishes an investigation team comprising members from relevant departments, Audit & Supervisory Board Members, and legal counsel to conduct the investigation.

If an investigation reveals misconduct, the President, the executive officer responsible for the relevant department, or the department head will promptly implement corrective measures and take disciplinary action against the offender in accordance with the company's regulations.

Whistleblower Protection

At the whistleblowing contact point, in accordance with the Internal Whistleblowing Regulations, Timee, Inc. designates the individuals responsible for handling contact point and investigation tasks and imposes strict confidentiality obligations on them. This ensures rigorous management of information, including details identifying the whistleblower and the content of the report, thereby protecting the whistleblower. Furthermore, the company strictly prohibits any adverse treatment or retaliatory actions against whistleblowers.

Training Programs

Timee, Inc. conducts compliance training once a year for all its employees (including contract employees, dispatched workers, and part-time employees). The content of the training program is selected based on the level of importance for that fiscal year from a range of topics, including the prevention of harassment, the importance of legal compliance, proper information management, the prevention of insider trading, and compliance with industry-specific laws such as the Employment Security Act. Through these efforts, the company strives to continuously improve its employees' awareness and knowledge of legal compliance.

Basic Approach to Political Engagement and Lobbying Activities

The Timee Group views the development of an environment where workers can work with peace of mind and operators can conduct their business properly in the rapidly expanding spot work market as a critical issue. In response, the group strives to ensure appropriate decision-making, expenditure management, and transparency in lobbying activities, in accordance with internal rules such as the Lobbying Policy. In its lobbying activities, the group disseminates case studies using statistical data and frontline insights on the "Spot Work Research Institute" website it operates. Furthermore, by participating in the "Japan Spot Work Association," the group collaborates with industry stakeholders to conduct activities aimed at the industry's sound development. Through dialogue with relevant ministries, agencies, and local governments, the group promotes initiatives to solve social issues while ensuring harmony with legal systems.

Political Contributions and Related Expenditures

To date, the Timee Group has not made any political contributions to political parties or individual politicians. However, to accurately grasp trends in related policies, the group may participate in policy study sessions, political fundraising parties, and similar events. When participating, the group complies with applicable laws and regulations, including the Political Funds Control Act, and handles these matters in accordance with internal management guidelines (such as the Lobbying Policy).

Expenditure Details

(Unit: Thousands of JPY) FY23/10 FY24/10 FY25/10 FY26/4
Political Contributions - - - -
Lobbying - - - -
Trade Associations etc. 2,653 3,429 4,711 2,375
Other Political
Expenditures
- - - -
Total 2,653 3,429 4,711 2,375
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