Code of Conduct

PHC Group’s Code of Conduct applies to all employees in every country we operate. In the Code of Conduct, 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.

Education and Training

Continuous training and education activities are essential for promoting compliance with company policies. In fiscal year 2025, we conducted training for all PHC Group employees on the critical topic of the Code of Conduct. The completion rate for the training was 100%. We will continue to provide necessary training to ensure compliance on this essential topic.

PHC Group Reporting System

PHC Group offers compliance helplines for use by employees, contractors and others. Employees, contractors and others are encouraged to report potential compliance issues, such as suspected fraudulent activity or human rights violations, by multiple methods, such as phone or email. Helplines can be used anonymously. In addition to contact points at each company, third-party reporting points such as law firms are available to help create an environment that facilitates consultation and reporting. Each PHC Group company is responsible for investigating and responding to any reported cases of noncompliance, and serious cases are handled by PHC Holdings Corporation in accordance with the escalation policy.