Introduction

Our Code of Conduct is based on the SoftBank Group’s ethical standards where we declare our commitment to conduct SoftBank’s business ethically: “We Commit to Integrity and Respect”, “We Commit to Being Customer Driven”, “We Commit to Transparency and Robustness”, “We Commit to Diversity, Inclusiveness and an Engaging Environment”, and “We Commit to Fair Business”. Action Statements under each standard provide specific guidance and describe the conduct and behaviors expected of each SoftBank officer and employee. By taking these actions we adhere to the highest possible standards of ethical business conduct. Fulfilling these commitments will help us Aim High and bring happiness to people around the world.

We expect all our officers and employees to know and follow the Code, Group policies and procedures. Moreover, while the Code is specifically written for the SoftBank Group officers and employees, we expect contractors, consultants, and others who may be temporarily assigned to perform work or services for the SoftBank Group to follow the Code. Failure to follow the Code can result in termination of their relationship with the SoftBank Group.

Different countries have different cultures, customs and laws. Does our Code apply worldwide?

Yes. Our Code establishes principles for ethical conduct applicable wherever we do business. Where there is a conflict between this Code and local customs, cultures or laws, we follow the higher standard of behavior.

The SoftBank Group, which includes SoftBank Group Corp.’s subsidiaries, will comply with all applicable laws and conduct its business ethically. For the SoftBank Group, ethical business conduct does not mean merely following the law but acting according to the highest ethical standards.

Employees

• Put company values into action in our daily work.
• Read, understand and follow our Code, policies and procedures.
• Report conduct that violates our Code.
• Ask questions and get help if you aren’t sure about the right thing to do.
• Cooperate fully and truthfully with any investigation.

Managers

• Act as role models.
• Create an environment where others feel safe to raise concerns and address them without retaliation.
• Promptly act on your team’s concerns and report to the relevant departments such as Human Resources, Legal or Ethics and Compliance.

To improve our operations, we rely on people in every part of our business to speak up about issues and concerns; and we expect everyone to act with integrity. Employees who come forward with concerns play an important role in maintaining our ethical workplace.

To encourage an open, candid culture we offer several reporting channels for you to ask questions and speak up:
▶ Your supervisor or manager.
▶ Human Resources.
▶ Legal or Ethics and Compliance.
▶ The Ethics Helpline.

You can access the Ethics Helpline via phone, email or written correspondence. In most countries you may submit concerns anonymously. In countries where this is restricted, you will be further advised when you contact the Ethics Helpline.

Speak Up!

• Is there a violation of our Code or policies?
• Has a crime been committed?
• Has there been a bribe, or do you suspect corruption?

• Is there danger to a person, the environment or property?
• Has a violation been hidden?

The SoftBank Group will not tolerate retaliation against those who raise genuine concerns, or participate in an investigation, or who refuse to participate in misconduct. Retaliation can occur in many ways and managers should get help from Human Resources to protect employees who have raised concerns or participated in investigations.

Examples of Retaliation:

• Change in compensation.
• Change in shift or hours responsibilities.
• Demotion.

• Termination.
• Poor performance review.
• Using the Ethics Helpline to make a false allegation.

Each company in the SoftBank Group is obligated to establish a system for complying with our Code, and a system for preventing and correcting violations.

• Each company in the SoftBank Group must establish relevant policies and procedures to supplement our Code and Group policies and to comply with applicable laws and regulations specific to each company. Officers, directors and employees must comply with these internal policies and procedures.
• Each company in the SoftBank Group may adopt its own code of conduct. However, each company’s code of conduct may not contradict or have lower standards than our Code except where our Code contradicts or violates applicable local laws.
• Group Companies are responsible for creating an environment in which any officer or employee who becomes aware of a violation or possible violation can easily report it without fear of retaliation.
• Group company employees may use the SoftBank Group Ethics Helpline or each company’s reporting channels to report misconduct or ask questions.
• Persons involved in any misconduct will be subject to discipline. If criminal activity has taken place, the SoftBank Group may report the matter to the appropriate authorities.

To ensure our employees can conduct our business safely and responsibly, the SoftBank Group requires employees to take periodic training that is appropriate for their roles and responsibilities.

• We take our obligation to train seriously and complete our training when it is due.
• Managers are responsible to ensure that employees complete required training on time.

Employees who fail to complete required training when due may be subject to management action.