Partners

DeNA Group Partner Guidelines

March 31, 2021

To all business partners, suppliers, and other business operators who support the activities of the DeNA Group (“Partners”)

DeNA Co., Ltd. (“DeNA”) expects that all officers and employees of DeNA and all subsidiaries of DeNA act based on the DeNA Group Code of Conduct and with the awareness of their respective positions as representatives of their organization, and in all aspects of corporate activities, to comply with laws, regulations, and company rules, and to practice behavior that conforms to social ethics in accordance with a high level of ethical standards. For purposes of the DeNA Group Partner Guideline (“Guideline”), “subsidiary” means a company more than 50% of whose voting rights are directly or indirectly owned by DeNA (together with DeNA, “DeNA Group”).

Each company should ordinarily be able to voluntarily choose whether to undertake such a code of conduct. However, for the products and services provided by the DeNA Group, DeNA recognizes the importance of having our Partners also understand and cooperate with the DeNA Group to act in accordance with this Guideline and fulfill their social responsibilities.

The DeNA Group has formulated this approach in this DeNA Group Partner Guideline (“Guideline”), and expressly stated the matters in which the DeNA Group expects the cooperation of all our Partners for transactions with the DeNA Group.

We sincerely appreciate the understanding and cooperation of our Partners with the intent and content of this Guideline.

Fair & Equitable Transactions

The DeNA Group complies with all applicable antitrust and competition laws and regulations in the countries in which we operate, and always strive to engage in fair competition with our competitors and contribute to the sound development of the market. In our relationships with all business partners, we are fully aware that they are indispensable to the development of our business, and we will respond to all business partners in a fair and sincere manner with a humble attitude and without forgetting our sense of gratitude. We will also strive to establish and maintain mutually beneficial business relationships with our business partners in accordance with sound business practices, while complying with all applicable laws and regulations.

• Compliance with Anti-Monopoly Act The DeNA Group deeply recognizes the importance of compliance with the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade (Anti-Monopoly Act) in order to maintain fair and free competition in our business activities, and has established the "Anti-Monopoly Act Guidelines" to ensure thorough compliance.
  These guidelines have been compiled to clarify specific guidelines and procedures for daily operations regarding compliance with the Antimonopoly Act. In addition, we conduct e-learning compliance training on the Antimonopoly Act for all officers and employees of our group companies in Japan to promote awareness of the Act. We will continue to promote fair transactions through ongoing training.
• Initiatives to Prevent Bribery The DeNA Group shall comply with the criminal laws of each country and domestic and foreign anti-bribery laws and regulations, including the U.S. Federal Foreign Corrupt Practices Act (FCPA), and shall under no circumstances engage in any conduct that could be considered bribery or offering of benefits to receive preferential treatment to public officials in Japan or overseas. In addition, all officers and employees of the DeNA Group shall at all times follow social common sense and sound business practices, and shall endeavor to avoid any conduct that could be considered a commercial bribe or receiving any personal benefit from a business partner. Any entertainment or gifts must be reported to the DeNA in accordance with internal rules.
  Based on the DeNA Group Code of Conduct, DeNA has established guidelines regarding entertainment and gifts to ensure appropriate relationships with business partners and other parties. In addition, we regularly conduct compliance training regarding these guidelines to maintain and raise awareness of compliance throughout the company.
• Initiatives to Reject Relationships with Antisocial Groups and ForcesFrom the viewpoint of social responsibility and corporate defense, the DeNA Group takes a resolute stance against any contact or unreasonable demands from antisocial groups and forces, and is resolute in our efforts to cut off any relationship with antisocial groups and forces. We have established an internal system to eliminate relationships with antisocial groups and forces, with the department in charge of administration as the managing department, and have formulated a response manual to prevent damage caused by antisocial groups and forces and to cut off or eliminate relationships with them. When selecting business partners, etc., the managing department conducts a check of business partners at the start of new transactions and on an annual basis in order to thoroughly eliminate any relationship with antisocial groups and forces.
  In order to disseminate appropriate methods of dealing with antisocial groups and forces, DeNA regularly addresses the management of business partners and responses to antisocial groups and forces as a theme in compliance training.

Receiving Reports from Partners

The DeNA Group operates a whistleblowing hotline for partner employees, among others. In addition to the internal contact point, DeNA also provides a contact point for the corporate auditors and outside legal counsel to ensure that whistleblowers can consult and report with confidence and confidentiality. The DeNA Group Code of Conduct and internal regulations stipulate the confidentiality of whistleblowers and the prohibition of disadvantageous treatment of whistleblowers.

*Page in Japanese, accepts English reports.
*This contact point is for reports and consultations regarding corporate ethics violations in the DeNA Group. For general feedback and questions to the DeNA Group, please contact us here. Please refrain from using this contact point for advertising or soliciting for various services.

Partnership Building Declaration