Subsidiaries

Established on November 1, 2007

Dwango Co., Ltd. declares the following compliance policy for on going development and to achieve our corporate mission while fulfilling our social responsibilities.

*Compliance is a responsibility shared by management and individual employees to abide by laws and legislation as well as a social code of conduct with a high sense of ethics that demands behaving with integrity.

1. To Behave According to Rules as a Member of Society

In business, management and employees must conduct fair dealings abiding by laws and a social code of conduct.
Management and employees must be aware that they are members of society, and must behave moderately.
All management personnel and other employees must conduct business faithfully and refrain from wrongdoing.
Management and employees must make fair decisions based unhindered exchange of opinions.

2. To Provide Services Satisfying Customers while Making an Effort Enhance Confidence in the Company

Management and employees must stick to the attitude of “customers first,” providing adequate explanations about dealings.
Management and employees must listen to customers faithfully and make use of the feedback in providing services.
Management and employees must keep a “sense of fun” in mind as they pursue customer satisfaction and profit simultaneously.

3. To Protect and Manage Information Adequately

Management and employees must strictly manage information acquired through business, abiding by the related laws and legislation.
Management and employees must build sophisticated information security environments and provide safe communication environments.
Management and employees must strictly abide by laws stipulating protection of personal information.

4. To Make Efforts in Adequate Disclosure of Information

Management and employees must handle information of the company adequately and refrain from conducting insider trading.
Management and employees must not make false statements in disclosing information.
Management and employees must not record false or misleading information in any accounting documents of the company.
Management and employees must adequately manage information to be stored, and allow the information to be disclosed as required.

5. To Keep Healthy Relations with Business Contacts

Management and employees must not have dealings with antisocial powers such as organized crime or racketeers.
Management and employees must compete with their counterparts in a sound manner and abide by antitrust law and other laws related with dealings.
Management and employees must keep fair and free relations with business contacts, and must not make unfair demands.
Management and employees must respect the intellectual property rights of third parties and use such property correctly.

6. To Establish Work Environments of High Moral Level

Management and employees must strictly abide by labor related laws, and make efforts toward establishing a fair and faithful corporate culture.
Management and employees must make efforts toward prevention of all types of harassment and maintain work environments of high moral level.
If harassment occurs, management and employees must not neglect the behaviors in question and must take strict actions.
Management and employees must respect the personalities of workers, and make an attractive working environment.