Our approach to compliance and risk management
To advance our mission and ensure sustainable development, we will not only comply with laws and regulations but also uphold the high ethical standards expected of us and our industry. We strive to foster a strict organizational culture anchored in compliance. We will implement comprehensive risk management across the company to prevent unforeseen losses and enhance corporate value. This involves identifying significant risks, taking measures to mitigate them, and establishing a system to promptly communicate and share risk-related information.
Compliance and risk management promotion structure
The Compliance Promotion Committee plays a central role in compliance and risk management, overseeing all related matters. To address compliance and risk management concerning sales operations, the committee collaborates with the Sales Review Department.
Compliance & Risk Management Promotion Structure (As of December 2025)
Compliance Promotion Committee
The Company has established a Compliance Promotion Committee to raise awareness of compliance within the Company and promote compliance from a companywide perspective. Chaired by a full-time director, this seven-member Committee meets monthly to discuss and promote compliance initiatives. The Committee considers measures to deepen the regulatory understanding of our officers and employees, cultivating a corporate culture rooted in sound governance, while also providing guidance to each department to prevent risks from occurring.
Operations Review Department
The Operations Review Department, which is independent of the sales departments and reports directly to the Directors, is responsible for auditing the sales compliance system, raising employee awareness, and formulating measures to prevent compliance violations and ensure robust remediation if they occur.
Compliance and risk management initiatives
Compliance and risk management policy
The Compliance Promotion Committee examines critical risks and reports them to the Executive Committee, which then discusses and determines our Business Continuity Plan (BCP). Additionally, the Executive Committee establishes crisis management protocols to address unforeseen risks. Based on these directives, the relevant departments develop and implement specific countermeasures.
Education and information sharing
In principle, compliance education is provided at least once a year to instill compliance awareness among employees. In addition, when important matters arise or when extraordinary action is required, information is shared as appropriate through all hands meetings, morning meetings, and internal communication tools.
Whistleblowing system
We have established a whistleblowing system to address any actual or suspected violations of laws, regulations, or internal rules, particularly in cases where resolving the issue through standard reporting lines is difficult or inappropriate. To ensure that whistleblowers are not easily identified and can report safely and securely, we have outsourced the whistleblower hotline to an external company with no vested interest in our organization.
To protect whistleblowers, we have developed whistleblower protection regulations and share information with the Human Resources Department to ensure whistleblowers are protected from any form of disadvantageous treatment. Additionally, those who engage in retaliatory actions against whistleblowers will be subject to strict disciplinary measures based on our internal regulations, such as employment rules, to prevent any disadvantage to whistleblowers.
In addition to the internal whistleblowing system, we have also set up an external point of contact on our website to receive reports from clients and other stakeholders.
Whistleblowing system
Number of whistleblowing cases
| FY2022/9 | FY2023/9 | FY2024/9 | FY2025/9 | |
|---|---|---|---|---|
| Number of whistleblowing cases | 0 | 0 | 2 | 0 |
Policies
Strike Code of Ethics
The Strike Code of Ethics articulates the fundamental principles that every executive and employee of the Strike Group must strictly observe across all aspects of our business operations.
1. Thorough Compliance
We uphold the highest ethical standards and strictly comply with all laws, regulations, and social norms.
2. Respect for Human Rights and Prohibition of Discrimination and Harassment
We respect the fundamental human rights of all individuals and strictly prohibit any form of discrimination or harassment.
3. Fair Business Practices
We refrain from any anti-competitive behavior and maintain fair and equitable relationships with our business partners.
4. Commitment to Clients
To fulfill client needs and build lasting relationships of trust, we are dedicated to providing high-quality service and acting with the utmost integrity.
5. Proper Use and Management of Corporate Assets
We appropriately utilize and manage corporate assets, taking all necessary measures to safeguard them.
6. Rigorous Information Security
We properly protect and manage the information of our clients, business partners, and employees, alongside our confidential and proprietary information assets, doing our utmost to prevent unauthorized access, data breaches, and falsification.
7. Prohibition of Bribery and Corruption
We strictly prohibit bribery, corruption, and malfeasance in all forms. We provide or accept entertainment and gifts only for legitimate business purposes and strictly within socially acceptable bounds.
8. Social Contribution and Environmental Conservation
We strive to protect the global environment and contribute to the sustainable development of society by addressing social challenges through our business operations and engaging in dialogue with local communities.
9. Appropriate Relationships with Political and Administrative Bodies
We maintain proper relationships with political and administrative bodies, strictly prohibiting any illegal or inappropriate donations or contributions that violate relevant laws and regulations.
10. Appropriate Information Disclosure
We ensure the timely and appropriate disclosure of accurate information to all stakeholders.
11. Prohibition of Insider Trading
We rigorously manage insider information and strictly prohibit insider trading.
12. Exclusion of Anti-Social Forces
We firmly reject any association with anti-social forces or other criminal organizations that threaten the order and safety of civil society.
13. Reporting of Compliance Violations and Prohibition of Retaliation
Upon discovering any suspected compliance violations, we promptly consult with or report to the designated compliance help desk or internal whistleblowing hotline. We strictly prohibit any retaliatory or disadvantageous treatment of individuals who raise such concerns.
Anti-Bribery and
Corruption Policy
Strike Group (“we,” “us,” or “our”) has established the following Anti-Corruption and Bribery Policy to conduct corporate activities in compliance with laws, regulations, and social norms, and to maintain the trust of society and stakeholders.
Scope of application
This policy applies to all officers and employees of the Strike Group.
Compliance with laws and regulations
Our officers and employees of Strike must comply with all applicable anti-corruption and anti-bribery laws and regulations in Japan and in all relevant countries and regions.
Prohibition of offering bribes
Our officers and employees are prohibited from offering or promising to offer any money, goods, or other benefits to public officials, business partners, or others with improper intent.
Prohibition of accepting bribes
Our officers and employees are prohibited from soliciting or accepting any money, goods, or other benefits with improper intent.
Lawful gifts and entertainment, and record keeping
Gifts or entertainment may be provided to business partners and other relevant parties only for legitimate business purposes and within a scope that aligns with accepted business practices. In providing entertainment, gifts, or other benefits, necessary procedures must be followed in accordance with internal rules, and accurate records of all transactions must be kept.
Political contributions
In principle, we do not make political donations, but if we were to do so, it must comply with all relevant laws and regulations.
Internal reporting system
We maintain a whistleblower hotline that allows employees and officers to report compliance violations, including cases of bribery and corruption. In addition, our internal regulations stipulate that whistleblowers must be guaranteed confidentiality and that any prejudicial treatment of whistleblowers is strictly prohibited. If a violation or potential violation by an officer or employee is discovered, an investigation will be conducted, and appropriate actions will be taken, including correction of the violation, disciplinary action against the violator, and formulation of measures to prevent recurrence.
Fundamental Policy on Antisocial Forces
Strike Group ("we," "us," or "our") establishes and complies with this fundamental policy to resolutely eliminate all ties with antisocial forces that threaten social order and safety (organized crime groups, members of organized crime groups, associate members of organized crime groups, companies affiliated with organized crime groups, corporate extortionists, and other similar entities).
We must sever all ties, including transactional relationships, with antisocial forces.
The entire organization will take action against antisocial forces in accordance with a separate internal policy. In addition, we must ensure the safety of the officers and employees who will deal with them.
We will establish close cooperative relationships with external specialized organizations such as the police, the National Center for Removal of Criminal Organizations, and attorneys to deal with unreasonable demands made by antisocial forces.
We will not accept any unreasonable demands from antisocial forces, and will take legal action, both civil and criminal, as necessary.
We will under no circumstances provide benefits to or engage in covert transactions with antisocial forces.
Tax Policy
Strike Group ("we," "us," or "our") is committed to social development and the fulfillment of its mission through fair and honest business activities in compliance with laws, regulations, and rules. With respect to taxation, we establish the following tax policy to ensure tax compliance and tax transparency.
Tax compliance
We will file tax returns and pay taxes in an appropriate and timely manner in accordance with relevant tax laws, regulations, and rules.
Tax governance
Our Director and Chief Financial Officer is responsible for establishing and maintaining tax governance and risk management systems. Day-to-day tax administration is managed by the Administration Department, where issues of particular importance and significant risks are reported to the Board of Directors. In addition, training and other programs are provided to employees as necessary to improve their tax knowledge.
Response to tax risks
We ensure that tax risks are properly managed by making prior inquiries to tax authorities and consulting with experts when tax laws are unclear, are subject to multiple interpretations, or as otherwise necessary.
Tax planning
We strive to optimize the tax burden by using preferential tax treatment to the extent reasonable for light of our business purposes. We do not use tax havens or tax structures for the purpose of tax avoidance.
Relationship with tax authorities
We build and maintain sound relationships with tax authorities. We respond in good faith to inquiries from tax authorities, and if differences of opinion arise, we endeavor to resolve them through constructive dialogue.
