I expect all officers, employees and business partners to observe high ethical standards in the performance of their duties, and to strictly adhere to the letter and spirit of all laws and group policies governing our business activities.

The Legal, Risk & Compliance (“LRC”) function – led by the KWE Group General Counsel and supported by the Head of Group Compliance – is available to provide guidance on ethical and legal questions, to help develop and train on new group policies, and to receive reports and oversee investigations into potential non-compliances.

Ultimately, every individual is responsible to speak out if they see any actual or suspected violation of appliable laws and group policies, and I ask that each of you does so openly and willingly to help maintain KWE’s reputation for accomplishment, fair dealing and ethical conduct.

Tetsuya Yamanaka – President & CEO, Kintetsu World Express, Inc.

Anonymity, Confidentiality, and Non-Retaliation

Reports may be made anonymously. We will endeavor to keep reports confidential and shared on a need-to-know basis only.

We strictly prohibit retaliation against any person for making a good faith report about any matter the person reasonably believes constitutes a violation of the law, the KWE Group Code of Conduct and/or KWE policies, or for participating, cooperating or assisting in any investigation, or providing testimony in any governmental proceeding.