Promotion and Reinforcement of Compliance

We comply with domestic and foreign laws and social norms, and conduct fair, transparent, and free competition, as well as appropriate business transactions.
"K" LINE (the Company) has established the “K” LINE Group's Charter of Conduct, under which compliance with laws, regulations, and corporate ethics is positioned as one of the fundamental principles guiding the behavior of the "K" LINE Group. As more concrete guidelines, based on resolutions of the Board of Directors, the Company has established the “K” LINE Group Global Compliance Policy (the Global Policy) , as well as individual policies that set forth specific compliance standards in areas such as competition law, anti-bribery, economic sanctions and anti-money laundering, and data protection. These policies are designed to strengthen the compliance framework of the "K" LINE Group at a global level and are mandatory for all officers and employees of the Company and its group companies, including contract employees and secondees. In addition, the Company’s dedicated compliance department regularly reviews and, as necessary, revises these policies and related compliance regulations in response to changes in laws and regulations and the business environment.
 

The Global Policy, which was approved by the Board of Directors, is designed to strengthen the compliance framework of the "K"LINE Group at a global level and mandates compliance by all officers and employees of the Company and its group companies, including contract employees and secondees. We work to ensure that the Global Policy serves as a practical guideline for the day-to-day operations of officers and employees through initiatives such as seminars conducted by the dedicated compliance department, the distribution of guidebooks, and the activities of specialized committees.

Through the Compliance Committee chaired by the President and Representative Executive Officer, the Company deliberates on policies to ensure compliance by the Company and its group companies, as well as on measures to respond to compliance violations.
In addition, under the supervision of the Chief Compliance Officer (CCO), who serves as the highest officer responsible for compliance, the Company is strengthening the compliance framework across the entire organization. The effectiveness and adequacy of the compliance management system are regularly reviewed, and the results are reported to the Board of Directors, where they are periodically discussed and examined.

As of April 1,2026

• Compliance Committee Rules
• Regulations for Compliance with the Antimonopoly Act
• Audit Procedures (Regulations for Compliance with the Antimonopoly Act)
• Rules Regarding Contact with Competing Companies
• Guidebook for the Antimonopoly Act Compliance Vol.1 — Cartel Q&A
• Guidebook for the Antimonopoly Act Compliance Vol.2
• Fair Competition Promotion Committee Operating Rules
• General Policy against Bribery and Corruption
• Regulations for Prevention of Bribery
• Guidebook for Prevention of Bribery Vol.1
• Regulations for Gifts
• Rules for Compliance with the Regulations Regarding Economic Sanctions
• Rules for Management of Personal Data
• Rules on Insider Information Management and Insider Trading
• Detailed Rules for Handling Compliance Issues
• Hotline System Rules (Whistleblowing System)
• Global Hotline System Rules (Whistleblowing System)

“K” LINE has established a “Hotline Desk” and a “Global Hotline Desk” to receive internal reports from officers and employees of the Company and its domestic and overseas Group companies, as well as a “Business Partner Consultation and Reporting Desk” to receive consultations and reports from business partners. These mechanisms are intended to prevent the occurrence of compliance issues and to enable the early detection and remediation of risks across our domestic and international business.
Anonymous reporting is available through the Hotline Desk and the Business Partner Consultation and Reporting Desk.
In addition, “K” LINE clearly stipulates in its regulations the confidentiality of information related to reports and strictly prohibits any unfavorable treatment of whistleblowers on the grounds of having made a report. By ensuring thorough protection of whistleblowers, “K” LINE has established a system that reporters can use with confidence.
 

With regard to compliance with domestic and international competition laws, the Company requires all officers and employees of the Company and its group companies (including contract employees and secondees) to comply with the Global Compliance Policy, which includes an individual policy on competition law.The Company also ensures that all officers and employees of the Company (including contract employees and secondees) strictly comply with the  Regulations for Compliance with the Antimonopoly Act.
Through regular training programs and continuous awareness‑raising activities conducted by the dedicated department, we work to further strengthen both its competition law compliance framework and awareness. The Company also conducts business audits on an annual basis to monitor and supervise the implementation status of compliance‑related measures. Furthermore, contact with competitors is strictly managed through prior notification and approval procedures, as well as the preparation, recording, and retention of the details of such contacts.

To enhance the effectiveness of anti-bribery measures, we regularly conduct anti-bribery training through the dedicated department for all officers and employees of the Company (including contract employees and secondees), as well as officers and employees of its group companies, in accordance with the Global Compliance Policy, which includes individual policies on anti-bribery laws.
In addition, as a member of the Maritime Anti-Corruption Network (MACN), which works toward the realization of a corruption-free shipping industry, “K” LINE continues to strengthen its initiatives to prevent corruption and bribery.

Based on the Global Compliance Policy, which includes individual policies on economic sanctions and anti-money laundering, the Company requires all officers and employees of the Company and its group companies (including contract employees and secondees) to strictly comply with economic sanctions regulations applicable to the “K” LINE Group’s business, as well as rules on anti-money laundering and counter-terrorist financing. Regular training on economic sanctions and related regulations is conducted by the dedicated department.
In response to the global trend toward increasingly stringent economic sanctions, we conduct thorough due diligence for new transactions and for cargo transportation to high-risk countries and regions, including the verification of parties involved in the transaction chain and capital relationships, in order to prevent violations of economic sanctions. Furthermore, we utilize services provided by external specialist firms to carry out continuous monitoring of business partners.

In light of the strengthening of laws and enforcement related to the protection of personal information in countries around the world, we have established policies on data protection and require all officers and employees of “K” LINE and its Group companies (including contract employees and secondees) to comply with them.
From a systems perspective, we implement technical measures such as access control and enhanced monitoring frameworks, and also exercise strict oversight over outsourced service providers, in order to reduce the risk of personal information leakage. Furthermore, through regular education and training programs for all officers and employees of the Company (including contract employees and secondees), as well as those of its Group companies, “K” LINE works to enhance awareness of the importance of personal information protection.

We designate November each year as Compliance Month, and to remind officers and employees of the Company and its group companies (including contract employees and secondees) of the importance of compliance, we distribute a message from the President, conduct compliance e-learning programs covering topics such as competition law and anti-corruption, and hold compliance seminars with external lecturers.
In addition, compliance training is incorporated into hierarchical human resources training programs, and seminars on specific topics, such as insider trading regulations and harassment prevention, are held as appropriate.
Furthermore, through the internal portal site “360°Compliance,” which consolidates relevant internal regulations and past compliance training materials, “K” LINE ensures that its officers and employees can access information at any time. We also continue our efforts to enhance compliance awareness by periodically distributing a “Compliance Newsletter” highlighting important compliance-related issues that require special attention.

Our Global Compliance Policy stipulates that we comply with applicable tax-related laws and international rules, pay taxes appropriately, and ensure tax transparency. We try to keep good relations with the authorities and not to engage in abusive tax planning, such as the use of tax havens to evade taxes.