Charter of Corporate Behavior

In order to realize our corporate philosophy, Japan Exchange Group has established a Charter of Corporate Behavior which each company of the Group shall use as a standard when coordinating efforts and conducting business.

I. Customer Relations (Investors, Listed Companies, Trading Participants, etc.)

Provision of High-Quality Services

As public infrastructure that supports economic activity, we will meet the needs of the times accurately and swiftly, look at things from the viewpoints of domestic and overseas customers (i.e. market users) including investors, listed companies, and trading participants, and also provide a variety of high quality services that fulfills the needs of such customers.

Improvement of Self-Regulatory Functions

In order to maintain fair and smooth transactions for which a focus is placed on investor protection, we will work as the market operator to further enhance self-regulatory functions and increase the appeal of the market.

Fair and Legal Trading

We will operate in a manner based on high ethical values with a consciousness of fair and appropriate trading. We will not pursue profits using improper or fraudulent methods, while maintaining an accurate understanding of and compliance with laws and regulations concerning corporate activities, such as the Anti-monopoly Act.

Distinction between Official/Private Matters and Prohibition of Preferential Treatment, etc.

We will draw a line between official and private relations. We will not engage in any dining or gift exchanges with business associates that exceed minimum levels of courtesy. Furthermore, we will not exchange any inappropriate services or benefits with people from public institutions at home or abroad or business related people.

II. Relations with Shareholders

Timely and Appropriate Disclosure of Information

Through the timely and appropriate disclosure of management information to investors (shareholders), we will fulfill our accountability and ensure the trust of our shareholders.

Prevention of Insider Trading

Because actions that violate insider trading regulations cause remarkable harm to the fairness and soundness of the overall market, we will take firm action against any activities which could be seen as unfair. Additionally, we will work to further spread awareness of the intent of such regulations with related outside people at client companies and so forth.

III. Public Relations

Maintenance of Stable Systems and Thorough Management of Risks

We will create highly reliable systems which meet needs in all areas, including competitiveness, convenience, and cost efficiency, while maintaining a constant awareness of our great responsibility as the central market of Japan and recognizing the priority of operating systems stably. We will consider the possibilities of system failures, natural disasters, and other unexpected events in running our market, and will remain committed to developing, enhancing, and stably running a system and framework designed to continue operating in such circumstances.

Compliance with Laws and Regulations

We will maintain an accurate understanding of and strictly comply with all laws and regulations related to our business, including the Financial Instruments and Exchange Act and Companies Act. Furthermore, we will conduct corporate activities in-line with social ethics and best practices, and commit our best efforts to problem prevention.

Contribution to Society

We will work to make broad contributions to society as a corporate citizen by responsibly and pro-actively conducting corporate activities to maintain and develop the health and welfare of the society. Additionally, we will encourage company officers and employees to independently contribute to society and pro-actively support such activities.

Public Communications

We will work to gain the trust of the public by proactively promoting communications with a variety of stakeholders through a diverse range of public relations activities.

Eco-Conscious Corporate Activities

With the goal of a sustainable society where "economic development" is compatible with "environmental protection", we will work to coexist with the natural environment in all our corporate activities through methods such as conservative use of energy and resources, reduction of waste, and promotion of recycling.

Sound Relations with Political and Government Entities

We will maintain proper and sound relations with all political and administrative organizations, and their affiliated entities, and operate with strict caution to avoid illegal actions and those which could be interpreted as collusive.

Firm Response to Anti-Social Forces

We will take a firm stance against anti-social forces which threaten the order and safety of society. We will work to block all relations with such groups and prevent their intervention in the market, thereby building a sound and fair market.

IV. Relations with Employees and Corporate Finances

Respect for Human Rights and Prohibition of Discrimination

We will give due regard to individual human rights and safety in the workplace, and work to ensure that employees can fulfill their potential in a pleasant and rewarding workplace free from discrimination and harassment.

Effective Use and Protection of Corporate Assets

We will put corporate assets to effective use. We will fully recognize the value of corporate assets, especially intellectual properties that JPX Group has developed as a knowledge industry, and make our utmost efforts to protect those properties through measures such as proactive registration based on the applicable laws. Furthermore, we shall avoid behavior that constitutes a conflict of interests for the company. We will respect the property rights of other persons and other companies - including intellectual property - and will not infringe upon those rights or use the properties of others illegally.

V. Thorough Management of Personal Information and Confidential Information

We will thoroughly protect all third party information, including personal information acquired in the course of conducting business, and will ensure that it is neither leaked nor used for anything other than its primary purpose. Additionally, we manage information acquired in conducting business to prevent leaks not only to those outside of the company, but also to unrelated officers and employees within the company.

Sound Corporate Ethics

JPX Group's compliance programs, including this Charter, play a vital role in internal control. Therefore, in order to fulfill the social role entrusted to us by the public, the JPX Group management will take the lead in realizing the principles of this Charter, and will thoroughly promote awareness within the company while developing an effective internal structure. If by any chance the principles of this charter are violated, the management will clarify the locus of the responsibility for the violation and deal with the situation in a strict manner.