Integrated Report 2025

Sustainability: GovernanceCompliance

Code of Conduct

PHC Group’s Code of Conduct applies to all countries and employees. It is organized by each of our values: Curiosity, Courage to Act, Respect & Collaboration, and Integrity. We focus on potential risks to our business and key principles for acting ethically and in compliance with company policies. We also comply with all applicable local, national, regional, and international laws, rules, regulations, and legal doctrines. If any conflict arises between our policies, standards, Code of Conduct, and applicable laws and regulations, we follow the most stringent applicable regulation.

Training and Education

Continuous training and education activities are essential for promoting compliance with company policies. In fiscal year 2024, we conducted training on the critical topic of preventing insider trading for all employees of PHC Group. The completion rate for the training was 100% (excluding employees who were unable to attend due to leave of absence, maternity leave, childcare leave, etc.). We will continue to provide necessary training to ensure compliance on this essential topic.

Internal Control Systems

PHC Group offers compliance helplines for use by employees. Potential compliance issues, such as suspected fraudulent activity or legal violations, can be reported. Helplines can be used anonymously. In various regions, third-party reporting points such as law firms are available, to help create an environment that facilitates consultation and reporting by employees globally. Each business unit is responsible for investigating and responding to any reported cases of noncompliance, and PHC Group has an escalation policy in place to handle any serious cases.