We commit to
Transparency and Robustness

We must disclose publicly certain financial and other information under our disclosure obligations, so we keep account books accurate and reflect actual business activities.

• We understand that financial information needs to be treated with great care, and that we must follow our policies and procedures.
• We fully and accurately record the company’s actual business activities in our account books, financial records, and other records.
• We also make fair, accurate, and timely disclosures and reports in accordance with the laws of each country where we do business.

If we are concerned that information in the SoftBank Group reports, systems or tools does not meet our standards, we voice those concerns to the appropriate level of management, or through the Ethics Helpline.

My manager is exerting pressure to “make the numbers work”, what should I do?

Your responsibility is to be honest and accurate. If you feel pressured to do otherwise, contact Legal or Ethics and Compliance.

Companies within the SoftBank Group may have legal requirements that regulate our external communications.

• We do not make any external statements about financial performance, internal matters or other company information to any investor or others, which should only be disclosed by each company’s department responsible for investor relations or corporate communications.
• We refer requests by an outside analyst to each company’s department responsible for investor relations.

We refer requests by a member of the media to each company’s department responsible for corporate communications.

The SoftBank Group encourages us to learn about and use social media such as video, blogs, wikis, podcasts, virtual worlds, and social networking. We follow good common sense when we use social media.

• When using social media, we will respect the reputation, privacy and intellectual property of others.
• We never disclose the SoftBank Group's inside information externally.
• We speak as individuals, not as SoftBank Group spokespersons.
• We do not disparage our competitors or others.
• We keep in mind that what we share is public and often permanent.

When the SoftBank Group plans to make acquisitions or investments we may be required to notify regulatory authorities such as the Committee on Foreign Investment in the United States (“CFIUS”) before we complete the transaction. We may be required to agree to restrictions in the way that we work with the investment or have access to the investment’s information.

• We always consult with Legal before we make a filing with the government.
• We are aware of and comply with our obligations under an agreement with the government such as a National Security Agreement (“NSA”) that may restrict our interactions with those acquisitions and investments.

If we are unsure about our interactions with investments, we contact Legal.

Examples of common NSA restrictions:

• Access to certain facilities or information may be limited to US citizens.
• Only US citizens may conduct certain critical business functions.

• Formal governance mechanisms that limit critical decision making to US citizens.
• Right of the US government to review certain business decisions and objects.

The SoftBank Group conducts investigations and audits of its businesses to ensure that as a company we comply with the standards in our Code and with applicable laws. When an investigation or an audit has closed, the SoftBank Group takes appropriate action to remediate any misconduct.

• We do not discuss an investigation with others, not even our line management; however, nothing in our Code or polices prohibits employees from reporting possible misconduct to government authorities.
• We cooperate fully and tell the whole truth when responding to an investigation or an audit.
• We recognize and follow “legal hold notices.”
• We never alter or destroy records in response to an investigation or audit, when an investigation or audit is anticipated, or when we have received a “legal hold notice.”
• We do not retaliate against another who has participated in an investigation or raised a concern.

If we see someone being retaliated against, we raise that concern to Human Resources, Legal, or Ethics and Compliance.

What is a“Hold Notice”?

Notification sent by a company facing litigation, a government investigation, or an audit to employees instructing them to preserve, and prevent the deletion, destruction or alteration of, relevant information and records of any kind including emails, instant messages or texts.

Example

For example, where an employee who has received a hold notice leaves the company, their laptop drive must be safely stored for later use.

Information systems are under attack every day.We will strive to identify vulnerabilities and risks and protect our systems and networks to avoid unauthorized access to our systems.

• We understand the great value of information and take care to prevent cyber-attacks and data leakage, alteration, or loss of material information we hold such as personal data, customer information and trade secrets.
• If we have a breach or suffer an attack, we will immediately report it to the relevant personnel in the SoftBank Group and the proper authorities; and we will make every effort to quickly recover from the damage, as well as prevent a recurrence.
• We plan and implement countermeasures based on environmental changes due to corporate acquisitions or the like, and we will ensure that countermeasures are effective and reliable by continuously assessing and reviewing them.
• We use only computer equipment, phones and internet-based services that the SoftBank Group provides or authorizes.
• We take care to not reveal passwords or accidentally allow access to our systems.
• We don’t click on suspicious links or open suspicious looking emails or messages.
• We use caution when downloading files and do not download from unknown sources.

We promptly report any potential or actual loss of the SoftBank Group information, or any potential breach of our systems or data to IT.

We use care to protect the SoftBank Group’s physical assets, as well as our intangible assets—our brand, reputation and valuable proprietary information, such as our intellectual property and confidential information.

• We properly manage and use company assets and will not use them for personal use unless otherwise allowed by each company’s policies, rules and procedures.
• We conduct company business using only those IT devices and services that are approved for use by our policies.
• We understand and follow the SoftBank Group and each company’s policies, rules and procedures for safeguarding our financial, intellectual property, and physical assets.

The SoftBank Group’s intellectual property distinguishes us in the marketplace. This includes our proprietary information, trade secrets, copyrights and patents, which we must manage and protect to out-perform our competitors.

• We protect our intellectual property by recognizing innovative ideas.
• We understand and follow each company’s policies, rules and procedures to protect our intellectual property and prevent loss or exposure.
• We exercise our intellectual property rights in an appropriate and reasonable manner without abusing them.
• We respect the valid intellectual property rights of others.

The SoftBank Group’s proprietary information is an asset and may be protected by trade secret, copyright or other important safeguards.

• When we receive confidential information from a customer, others or within the SoftBank Group, we make sure we understand our legal obligations and follow them.
• We use confidential information only as permitted and only for the purpose provided. After that purpose has passed, we dispose of copies of the materials, unless otherwise required by law, contract or our policies.
• We do not review, discuss, disclose, copy or use any copyrighted, licensed or confidential information except as authorized.

We do not share confidential information, unless it has been approved in advance by the information owner.

Our brands are valuable assets that bring reliability to customers.

• We properly use SoftBank brands as well as the brands each company holds in accordance with the SoftBank Group Brand Management Policy and each company’s policies, rules and procedures.
• We maintain and increase the value of our brands by the way we conduct ourselves and our business.

If we believe our brands are being damaged or violated by others, we raise our concerns promptly to Brand Management.