Harassment Prevention Policy

The term “harassment” in this Policy refers not only to power harassment, sexual harassment; harassment related to pregnancy, childbirth, childcare leave and caregiver leave; and customer harassment in the workplace as stipulated in laws and regulations, but also to any words and actions that unjustly harm or damage the other party's personality and dignity by harassing them or causing them to feel uncomfortable, etc.

SBI Investment Co., Ltd. (hereinafter, “the Company”) aims to constantly contribute to the maintenance and development of society based on its Mission Statement of becoming the leader in creating and cultivating core industries of the 21st century as a “New Industry Creator” (Mission Statement | SBI Investment Co., Ltd.). Harassment is a socially unacceptable act that unjustly impairs an individual's dignity and personality. Harassment is incompatible with the Company's Mission Statement and cannot be tolerated.
Structurally, the Company may hold a superior position over investees and prospective investees in the Company’s business of operating and managing venture capital funds, etc. Harassment in the course of business not only tarnishes the social reputation of the Company, but also hinders the development of the investment industry and impairs the maintenance and development of society.
The Company will pursue its corporate activities aimed at creating good relationships and a work environment free from harassment in accordance with the Company's Mission Statement.

The Company will do its utmost to take the necessary measures with due consideration so as to ensure that the Company’s officers and employees (permanent employees, contract employees, indefinite-term contract employees, senior employees, part-time employees, dispatch workers, employees on secondment from other companies, etc.) (hereinafter, “Company Officers and Employees”) as well as investors, prospective investors, investees, prospective investees, business partners and all other parties closely related to the Company's business (hereinafter, “Company Stakeholders”) are respected as individuals and are never subjected to harassment.
The Company will post this Policy on the Company’s website and conduct training to raise awareness about the prohibition of harassment.
To allow for consultation with peace of mind, the Company will establish a harassment consultation service which respects the protection of privacy and will not subject anyone to adverse treatment on the grounds of having made a consultation.
If a case of harassment is reported, the Company will properly ascertain the facts and, if harassment is confirmed, take strict disciplinary action or other appropriate measures in accordance with the Rules of Employment, Detailed Rules for the Prevention of Harassment, and other internal regulations, etc.

• 1.

  Publicity and raising awareness
  The Company will post this Policy on the Company’s website. Furthermore, the Company will provide Company Officers and Employees with education and training aimed at eradicating harassment in order to raise awareness of the prohibition of harassment.
• 2.

  Establishment of a consultation system
  The Company will establish a consultation service that Company Officers and Employees can use to make reports, and will assign personnel to handle consultations.
• 3.

  Prompt and appropriate response
  The Company will endeavor to ensure that personnel handling consultations on harassment cases investigate the matter as promptly and appropriately as possible and accurately ascertain the facts.
  If the results of investigation into the facts confirm that Company Officers and Employees have engaged in harassment, the Company will take disciplinary action or other appropriate measures in accordance with the Rules of Employment, Detailed Rules for the Prevention of Harassment, and other internal regulations, etc.
  The Company will respond resolutely to any incidents of harassment that occur and take appropriate and necessary measures, such as improving the workplace environment and formulating measures to prevent recurrence.
• 4.

  Prohibition of adverse treatment
  The Company prohibits any adverse treatment against those who have consulted with the harassment consultation service (hereinafter, “consulters”) as well as those who have cooperated with the Company's investigation into incidents of harassment and other related parties (hereinafter, “investigation collaborators, etc.”). In addition, the Company will take measures in consideration of consulters as well as measures against those who have subjected consulters or investigation collaborators, etc. to adverse treatment, as necessary.
• 5.

  Protection of privacy
  The Company will respect and protect the privacy of consulters and investigation collaborators, etc. to the fullest extent in harassment consultation and investigation.