Message from our CEO

I would like to share with you our revised version of the “PHC Group Code of Conduct.“ This Code of Conduct is a promise to society, reflecting the principles for the PHC Group to conduct our business activities at a high standard as a global healthcare company.

In November 2024, PHC Group announced our new vision and values, which unite our businesses across the globe to realize a future with high-quality healthcare accessible to all.

For the PHC Group to pioneer the future of healthcare through its business activities, it must uphold a high sense of ethics as a socially responsible company, build trust with diverse stakeholders, and fulfill its accountability to society. Particularly in the healthcare industry, where numerous laws and self-regulatory standards are in place, this Code of Conduct has been created with these considerations in mind. We firmly believe that by adhering to this Code of Conduct, we will meet these societal expectations.

I am fully confident that each and every employee of PHC Group will act upon this Code of Conduct and will work together as “One PHC“ to build a future of better healthcare for people across the world. Let’s “live our values”.

Role and Position of the Code of Conduct

This PHC Group Code of Conduct is designed to guide employees in the execution of the PHC Group’s daily business activities and tasks, in alignment with our mission, vision, and values. To realize our mission and vision, it is crucial to embody the values of “CURIOSITY,” “COURAGE TO ACT,” “RESPECT & COLLABORATION,“and “INTEGRITY.“ This Code of Conduct has been created to ensure that everyone understands how to practice these values in their daily activities and actions.

It is not possible for this PHC Group Code of Conduct to cover every situation or scenario you may encounter. Nevertheless, this Code of Conduct is intended to provide guidance that can be applied in all circumstances. As a global healthcare company, it is essential for the PHC Group to not only adhere to this Code of Conduct but also to comply with the applicable Laws and Regulations (*) in each country and region where we operate. We ask that you adhere to the strictest requirements among applicable Laws and Regulations, this Code of Conduct, and Internal Rules (*), and act accordingly.

Finally, as reflected in our value of “INTEGRITY,“ it is important to conduct ourselves ethically and responsibly based on this PHC Group Code of Conduct. We believe this is the foundation supporting our business activities as the PHC Group. Each of our actions and business activities embodies the PHC Group, so we ask for your commitment to act in accordance with this Code of Conduct.

• * For the purposes of this PHC Group Code of Conduct, the following definitions apply:
  Laws and Regulations：Refers to applicable national and regional laws, directives, regulations, guidelines, international standards, and industry codes or rules.
  Internal Rules：Refers to applicable rules and standards, policies, procedures, and work instructions, of PHC Group.
• * Please be advised that “Examples of Key Relevant Laws and Regulations” do not cover all applicable laws and regulations and are effective at the time of revision of this Code of Conduct. If you have any questions or need further clarification, feel free to reach out to the Legal and Compliance team members in your region.

Regarding Revision of the Code of Conduct

About four years have passed since the establishment of the first PHC Group Code of Conduct in 2021. As a global healthcare company, we have decided to completely review and revise the entire Code of Conduct. In revising our Code of Conduct, we have aimed to respond to changes in our business environment and societal expectations. Additionally, we have taken care to ensure that the content can be universally applied to any country or region, while striving to make the structure and expressions simple for PHC Group employees to understand. The content has been classified and organized from the perspectives of stakeholders such as “Customers” (“Providing Value to Customers”), “Employees” (“Safe and Secure Working Environments” and “Lawful and Fair Business Activities”), “the Company” (“Protection of Management Resources”), and “Society” (“Fulfilling Social Responsibility”). Moreover, we have re-evaluated the overall content from the perspective of a company engaged in the healthcare business and have added necessary elements. As a new initiative, we have also included major relevant laws for each section. While not exhaustive of all applicable laws, we hope this will aid your understanding.

We encourage you to read this revised PHC Group Code of Conduct with a fresh perspective. We trust that this Code of Conduct will support each employee in practicing our mission, vision, and values, and serve as a guide for making correct decisions and actions.

Contents

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PHC Group of Conduct

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• Providing Value to Customers
• Safe and Secure Working Environments
• Lawful and Fair Business Activities
• Protection of Management Resources
• Fulfilling Social Responsibility

Raising Questions and Concerns (Speak Up)

Any actions that violate Laws and Regulations or ethical standards may cause significant harm to the PHC Group and its stakeholders. To maintain trust in the PHC Group and transparency, in our business activities, employees are required to actively raise questions and concerns of any suspected unethical or improper conduct. This proactive approach enables the early identification and resolution of issues through corrective actions.

If you become aware of actions that violate or may potentially violate Laws and Regulations, the PHC Group Code of Conduct, or Internal Rules, do not ignore them. Promptly report or consult with your supervisor, a nearby workplace manager, or a designated contact point. Additionally, you can report or consult anonymously through the reporting hotline for your region.

The PHC Group does not tolerate any unfavorable treatment or retaliation against individuals who report suspected issues in good faith or who provide information or otherwise cooperate in good faith in the company’s investigation of suspected issues. Unfavorable treatment or retaliation of whistleblowers or others who report suspected misconduct or cooperate in the investigation of suspected misconduct also are prohibited by Laws and Regulations, and Internal Rules.
The PHC Group protects employees and business partners who raise questions and concerns in good faith.

Message from Senior Executive Corporate Officer in charge of Legal Affairs

Since taking on the role of Corporate Officer responsible for Legal Affairs in 2022, one of my goals has been to revise the PHC Group Code of Conduct. The first Code of Conduct was formulated in our journey from the carve-out of the Panasonic Group in 2014 to our listing on the Tokyo Stock Exchange in 2021. With this new edition, we sought to make it easier to understand, and more appropriate for a global healthcare company. I believe we have succeeded in the revision consistent with these aspirations.

During the preparation, we had multiple discussions with Legal and Compliance team members including the legal officers in the U.S. and EMEA, then elaborated on the draft, and finally reviewed it with our head office functions. We are grateful for the efforts of all of you involved in developing the new Code of Conduct.

I trust that this new PHC Group Code of Conduct will serve as a guideline for all employees in their daily activities. As a new initiative, we have included relevant laws and regulations in each section to help you to have better understanding.

I am assured that we can further enhance the trust and reputation of PHC Group as each of us fully comprehends this Code of Conduct and practices our day-to-day activities complying with it.