Whistleblowing Policy

Internal Whistleblowing System

Myria has established an internal whistleblowing system to detect bribery and corruption, accounting fraud, and other compliance issues that could occur as early as possible and take corrective steps.

Whistleblowing Channel for our partners

As a part of preventing cases of misconduct by any person of Myria and Myria Group companies, a whistleblowing channel has been established for its subcontractors, suppliers, and other stakeholders.

1. Applicable occasion
   • “Improper conduct” means any conduct which, if proved, constitutes a disciplinary offence or a criminal offence. Examples of what would constitute an “improper conduct” and be of “Concern” include, but not limited to the following:
     • improprieties in matters of financial reporting;
     • breach of the Myria’s codes of conduct, standards policies, procedures, practices etc;
     • fraud, corruption, bribery or blackmail;
     • failure to comply with laws, rules and regulations;
     • endangerment of an individual’s health and safety;
     • misuse of Myria’s property;
     • theft or embezzlement;
     • any unlawful act, whether criminal or civil in nature; and
     • concealment of any or a combination of the above.
   • Making an accusation against any kind of improper conduct by any person of Myria and Myria Group companies.
   • Reporting requests for complicity in misconduct by any person of Myria and Myria Group companies.
   • Consultation on withdrawal from cooperative misconduct.
   • We will not respond to factually inaccurate claims, such as slander against individuals.
   • Misconduct is defined as any act that violates compliance, including accounting irregularities, requests for money or entertainment, human rights violations such as harassment or nonpayment of wages, intentional cover-ups of construction defects, and information security violations.
2. Applicable person
   • Any level of officers and employees of our subcontractors and suppliers.
3. Reporting Channel

   Disclosure/ report can be made to any of the following dedicated reporting channels:

   By a formal letter, attention to:
   
   CEO of Myria Residential Co., Ltd.
   “Private and Confidential”
   Myria Residential Co., Ltd.
   Yurakucho Denki Bldg. South 14th Floor
   1-7-1 Yurakucho, Chiyoda-ku Tokyo 100-0006

   By a formal report to dedicated email address:

4. Disclosure of Report

   Any disclosure made should contain the following information:

   • description of the alleged event or matter (i.e., the nature of allegation; where and when the alleged misconduct/wrongdoing has taken place);
   • details of the person(s) involved;
   • other relevant information; and
   • any supporting evidence if available.
5. Confidentiality

   All information received will be treated as strictly confidential, save for disclosure on a “need to know” basis to facilitate investigations and/or take appropriate actions for such investigations.

6. After Reporting

   It shall be the policy of Myria and Myria Group to handle investigations promptly and as fairly as possible. Investigation after reporting and protection of whistleblowers will be conducted in accordance with the Company's whistleblower rules.

7. Protection for Whistleblower

   It shall be the policy of Myria and Myria Group to protect whistle-blowers who disclose concerns, provided the disclosure is made:

   • in the reasonable belief that it is intended to show malpractice or impropriety
   • to an appropriate person or authority; and
   • in good faith without malice or mischief.

   While all disclosures resulting from whistleblowing shall be treated with high level of confidentiality, employee and other relevant stakeholders are encouraged to disclose their name to make the report more credible, but we also accept a reporting under anonymous disclosure.

   Whistleblowers must ensure that they do not make disclosure outside of the prescribed channels (e.g. media-print or electronic), or their disclosures may not be protected.