We Commit to
Integrity and Respect

The SoftBank Group relies on its employees to make business decisions based on the best interests of the SoftBank Group, without being influenced by personal interests. Our commitment to make the SoftBank Group thrive means we never put personal interests above our duty to the SoftBank Group and each other.Even the mere appearance of a conflict of interest can be damaging to our reputation.

• We understand and look for conflicts of interest.
• We disclose our personal interests that might conflict with our company’s interests by following our policies.
• We do not take advantage of SoftBank Group information by acquiring interest in property or other assets that may conflict with the SoftBank Group’s interests.
• We are aware of our fiduciary obligations to customers and follow them, even when the obligation may conflict with the interests of the SoftBank Group. In those situations, we follow our policies to manage any conflict.

When does a “Conflict of interest” occur?

A “Conflict of interest” occurs when an individual’s personal interest interferes in any way—or even appears to interfere--with SoftBank’s interests. Conflicts arise when we use our role at the company, or information to which we have access, to personally benefit.

Examples of Conflicts:

• Working for a competitor, customer or supplier as an employee or officer.
• Accepting gifts, loans or investment opportunities from our business partners.
• Buying products, services, property or other interests that are of interest to SoftBank.
• Directing contracting opportunities and other transactions to yourself or those related to you.

• Taking for yourself a business opportunity related to the use of the SoftBank Group’s assets, information, relationships or position at SoftBank.
• Hiring a relative as a subordinate without disclosing the relationship to our supervisor.
• Purchasing a product or service we don’t need to help a business partner meet financial objectives.

The SoftBank Group expects its workforce to act with integrity and honesty. Regardless of the amount of an actual or potential loss, any fraud is a violation of our Code and is a criminal offense in many of the jurisdictions in which we operate. The SoftBank Group will take appropriate disciplinary action, up to and including termination of employment, when internal fraud occurs. Every employee should be aware of and look for the following types of fraud:

• A deliberate misuse of the SoftBank Group resources or assets for monetary gain. For example, authorizing payment for goods or services that were never received, or for receiving kickbacks.
• Misappropriation of business opportunities that are discovered or created as a result of the use of the SoftBank Group’s assets, including information, relationships or position.
• False reporting for personal gain or obtaining an unfair advantage, e.g. expense fraud or alteration of any internal document to obtain a better annual performance review.
• Misuse of the SoftBank Group’s data or intellectual property to obtain personal gain or an unfair advantage, e.g. theft and resale of personal data or a trade secret.

We are responsible for submitting timely, accurate and complete expense reports in accordance with each company’s travel and expense policies.

• We submit expense reports promptly, including per diem when allowed and, where permitted, for expenses incurred including meals eaten, miles driven, taxis taken, and airline tickets used.
• We remain responsible for the accuracy of our expense reports even if others prepare them for us.
• Managers are responsible to ensure the accuracy and appropriateness of their employees’ expense reports.

Many countries have laws prohibiting people from using or sharing with others nonpublic information referred to as “material nonpublic information” or “inside information.” This includes information that generally is not available to the public and that could, if publicly known, affect the market price of a company's stock. These laws can apply to individuals who may face severe penalties including prison terms.

• We strictly manage access to and use of inside information.
• When we have access to inside information about the SoftBank Group or other companies, we do not purchase or sell those companies’ stock or other securities until such inside information is publicly disclosed.
• We don’t share inside information with others who are not authorized including families and friends. It can be a crime to share or “tip” inside information to others, even if the information is not used to purchase or sell securities.
• We are very careful to avoid discussion of inside information in public where others can hear us, such as restaurants and when travelling.

Material Nonpublic or Inside Information

Information that an investor would see as important in deciding to make an investment:

• Financial information about the SoftBank Group, including earnings, profits, or dividends.
• Major business transactions, including a merger, divestiture, new contract or project, new business strategies, etc.
• Changes in management, serious information leakage or major litigation.

As good corporate citizens we engage in lawful and appropriate political activities on our own as individuals. To help us engage in the political process lawfully:

• We participate in the political activities of our choice.
• We may not participate on behalf or in the name of the SoftBank Group.
• We do not use any funds, assets or facilities in the SoftBank Group to contribute to politicians, including political candidates, parties, or organizations.
• We do not meet with or communicate with politicians including political candidates or government officials on behalf of the SoftBank Group unless authorized by the company.