VALUE COMMERCE

Environment

To reduce emissions of CO2, one of the greenhouse gases considered to have a significant impact on global warming, we have begun our efforts by measuring the CO2 emissions emitted from the business activities of the ValueCommerce Co., Ltd. and its subsidiaries (hereinafter, the “Group”).

Looking ahead, we will formulate a policy on CO2 emissions reductions once we have ascertained the current situation.

By introducing digital technologies across our entire operations and digitizing internal documents and invoices, we are making every effort to minimize the amount of paper we use through printing.

Additionally, we use dedicated recycling boxes (“Mamoru-kun,” operated by Japan Purple Inc.) for used documents to balance the need for confidentiality and recycling.

Since May 2021 ValueCommerce Co., Ltd. (hereinafter, the “Company”) has been a tenant of Tokyo Garden Terrace Kioicho. The building strives to improve its environmental performance and has been continually certified under the highest grade of the DBJ Green Building certification system administered by the Development Bank of Japan. As a tenant, the Company will contribute to the environmental and energy conservation efforts promoted by the building.

Environmental and energy conservation efforts underway at Tokyo Garden Terrace Kioicho(External site)

Social

Third-party Certification

All businesses operated by the Group have undergone review by third-party organizations and obtained certification for ISO/IEC 27001:2013, the international standard for ISMS, as well as JIS Q 27001:2014, the equivalent Japanese standard.

Information Security Management System

To ensure the information security of the Group, the Company has developed an information security management system consistent with the requirements of third-party certification standards.

The divisions responsible regularly report to the Board of Directors on the response status for information security-related risks.

The Risk Management Committee, which consists of full-time directors, manages the response status of information security-related risks.

The Internal Audit Office conducts periodic internal audits regarding information security and reports the results to full-time directors and the Audit and Supervisory Committee which consists of outside directors.

Security Training

Information security training is conducted for all employees, with the aim of having information securely guarded in daily business operations, even if not always attentive.

Implementation Status

Personal Information Protection

Policy

The Group appropriately manages the personal information in its possession based on its Privacy Policy, Action History Information Protection Policy and Service Terms of Use.

• Privacy Policy(details here)
• Action History Information Protection Policy(details here)

Handling of Requests Regarding Personal Information

When we receive a request from an individual to disclose the personal information we hold on them, make amendments, additions or deletions to that information, cease use, erase the information or cease its provision to third parties, we will respond appropriately and promptly.

ValueCommerce affiliate program has formed technical alliances with Spider Labs, Ltd., which has obtained technical certification from the world-class certification body Trustworthy Accountability Group (“TAG,” hereafter) for ad fraud measures and brand safety, and with Momentum, Inc., which maintains a database that analyzes around 30 million domestic advertising sites covering the major ad platforms (companies that serve ads).

These technologies are applied to all advertisers that use our services.

In addition, ValueCommerce affiliate program conducts independent visual reviews of all media at the time of registration, and operates a network that only comprises the sites that have passed its review.

To achieve sustainable growth into the future, we work to develop new businesses by clarifying the business fields, markets, customers and technologies to be targeted, and taking on the challenge of innovation.

To cultivate and retain human resources who will look at essential issues amid a rapidly changing business environment and commit themselves to achieving results by working autonomously without fear of change, we are pursuing a number of initiatives to foster a corporate culture that encourages challenges, to enhance our development programs, to provide wide-ranging career paths, and to achieve fair evaluations and compensation.

Human Resource Systems and Welfare Benefits(details here)

Employee Surveys

To quantitatively ascertain details about the organization, employee satisfaction and conditions while making continual improvements, we periodically conduct engagement surveys every year and continuously measure our “engagement score” to visualize whether individuals or organizations are in a position to maximize their performance or if there are any factors preventing them from demonstrating their abilities. This is useful for employee self-management and for organizational management on the part of managers.

We periodically conduct condition check questionnaires to ascertain the mental and physical health of employees operating under remote work conditions. This enables us to detect employee issues early on and facilitates employee self-care and line-care.

Establishment of Employee Points of Contact for Reporting and Consultation

To report compliance violations and harassment, we have set up points of contact in the Legal Affairs Division and Human Resources Division, full-time Audit and Supervisory Committee Members, parent companies and outside law firms contracted with parent companies.

We are contracted with an outside EAP(Employee Assistance Program) organization as a contact point for all manner of concerns and consultations, including mental or physical issues, interpersonal relationships at the workplace, daily duties and future career options.

Every director and employee of the Z Holdings Group will contribute to the development of a sustainable society by respecting human rights in every aspect of corporate activities. Such a stance is reflected in the “Basic Policy on Human Rights (Human Rights Policy)”.

As a member of the Z Holdings Group, the ValueCommerce Group has been advancing the policy.

Human Rights Policypdf

Governance

(Details here)

The terms of transactions with controlling shareholders are determined rationally based on designated procedures in light of the same contractual terms and market prices as when transactions are conducted with other companies.

Of the Company’s parent companies, the parent company deemed to have the greatest impact is Z Holdings Corporation, and Yahoo Japan Corporation, which shares the same parent company, is the company’s main business partner.

The Company has brought on people with extensive experience and knowledge of the Internet industry from Yahoo Japan Corporation to serve as the Company’s directors, and has received advice and proposals regarding efficient business operations from these directors.

The Company provides and purchases services from Yahoo Japan Corporation. The terms of the service provision and purchase are determined upon negotiation similar to general terms of transaction, or in consideration of market rates and contracting details.

To ensure independence from its parent companies, the Company has prescribed procedures for resolutions and reports made at Board of Directors meetings regarding transactions with the parent company and other companies that share the same parent company and have a great impact on the Company in a “Table of Administrative Powers.” the Company Board of Directors thoroughly reviews and confirms the rationality of transactions and validity of terms of transaction regarding all important transactions made with the parent company group.

As no operating limitations are imposed by the parent company and the Company is in a position to make independent management decisions, we believe that a certain degree of independence from the parent company is maintained. In addition, we regard collaboration with the parent company group to be business opportunities and believe such endeavors will lead to the Company achieving a competitive advantage over other companies.