Anti-Bribery Policy

1

Purpose

HOIST Corp. (hereinafter "HOIST") is committed to conducting its business with integrity and the highest ethical standards. To this end, HOIST strictly prohibits bribery and corruption in all its forms, complies with all applicable laws and regulations, both domestic and international, and acts with a high level of ethical awareness. By adhering to these principles, HOIST aims to earn the trust of society and enhance its corporate value.

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Scope

This Policy applies to all HOIST officers and employees (including full-time employees, contract employees, part-time employees, temporary employees, and dispatched employees). HOIST also requires its business partners, consultants, agents, and other third parties involved in HOIST's business activities to understand and comply with the intent of this Policy.

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Definition of bribery

For the purposes of this Policy, bribery refers to the following acts:

(1)Offering a bribe

Providing any benefit, including money, goods, services, or any other advantage (hereinafter referred to as “Benefits”) to public officials or employees of companies, etc., for the purpose of obtaining improper advantages.

(2)Receiving a bribe

Using one’s authority to receive Benefits for the purpose of obtaining improper advantages.

4

Prohibited Activities

All HOIST officers and employees are strictly prohibited from engaging in the following activities:

(1)Bribery of Public Officials

Providing Benefits to domestic or foreign public officials in relation or in connection with their duties.

(2)Bribery of Company Employees

Providing Benefits to employees of companies, such as business partners, with the aim of obtaining improper advantages.

(3)Solicitation or Acceptance of Bribes

Using one’s authority or in connection with one’s duties to solicit or to accept Benefits.

(4)Restrictions on Entertainment and Gifts

Entertainment and gifts provided to public officials or company employees must be limited to what is socially acceptable, and must not be excessive in a way that could influence the recipient’s business.

5

Risk Management System

HOIST has established the following system to appropriately manage bribery risks:

(1)Identification and Assessment of Risks

Identifying bribery risks in business activities and evaluating the likelihood and impact of their occurrence.

(2)Implementation of Preventive Measures

Taking preventive measures to reduce bribery risks, such as establishing internal regulations, providing training, and performing internal audits to reduce bribery risks.

(3)Detection and Response

Establishing a system to detect and respond appropriately to bribery and corruption incidents as early as possible.

6

Education and Training

HOIST provides regular education and training to officers and employees on anti-bribery laws, and regulations related to bribery and corruption, internal regulations, and ethical guidelines.

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Whistleblower System

HOIST has established a system that allows for prompt internal reporting of any suspected violations related to bribery.

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Response to Violations

HOIST will take strict action against any violations related to bribery. Disciplinary actions, claims for damages, and other measures will be taken based on the internal regulations, depending on the nature of the violation.

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Continuous Improvement

HOIST continuously reviews and improves its system for preventing bribery.