Governance

Compliance

1 | Code of Conduct

The MUJI Vision: The Quest for the Good Product

There is no one answer to what a good product is. Simply asking the question, though, creates infinite possibilities, and we pursue them.

Corporate Philosophy

Quest Value: Identify and deliver MUJI value and appeal from the perspective of the people who use our products.

Positive Spiral: Work toward global growth and development by operating a fair and transparent MUJI business.

Best Partnership: Deliver the abundance inherent in good products by respecting associates and building relationships of trust with business partners.

Code of Conduct

1. Quickly and carefully respond to customer needs

2. Think and act globally

3. Prosper together with local communities

4. Act sincerely and honestly

5. Be open to communication

2 | Compliance Code of Conduct

"Ryohin Keikaku Group Compliance Code of Conduct"

Goals

This Code of Conduct is established to ensure that each and every one of our colleagues in the Ryohin Keikaku Group understands the importance of complying with laws, regulations and corporate ethics based on our corporate philosophy and to fulfill our corporate social responsibility.

Basic Attitude

Act sincerely and honestly

1. Comply with domestic and international laws and regulations and internal company rules.

2. Act with good sense and responsibility as a member of society.

3. Earn the trust of all those associated with Ryohin Keikaku.

4. Ryohin Keikaku takes a firm stand against anti-social forces and does not provide any benefits.

Compliance Matters

1. Products and services

(i) We aim to provide products and services from the customer's perspective.

(ii) We will make sure to provide products that meet the safety and quality standards set forth in the relevant laws and regulations.

(iii) In the unlikely event of an accident or problem with a product or service, appropriate actions will be taken immediately.

2. Fair dealing

(i) Both we and our partners are aware of our corporate social responsibility; thus, we make sure to comply with laws and regulations. We will respect the characteristics and culture of each region, take the global environment and work environment into consideration, and work to improve the safety of our products.

(ii) We will deal in materials and services required under fair dealing relationships with appropriate quality, price, and delivery dates.

3. Respect for working colleagues

(i) We aim to achieve lasting happiness for our fellow employees who are associated with MUJI.

(ii) We pursue the mental and physical comfort, enrichment, and professional growth of all of our employees.

(iii) We respect the individuality, human rights, and privacy of our employees. We also make sure to eliminate discrimination and to not tolerate harassment of any kind.

(iv) We respect diversity in terms of gender, nationality, ethnicity, religion, etc., and we aim to learn from our differences and help each other grow.

4. Respect the environment

(i) We will restrict or discontinue the use of substances suspected of having a serious impact on the human body and the environment, and, if used, we will immediately disclose information about them.

(ii) We strive to ensure the traceability of natural materials.

(iii) We strive to reduce waste by integrating modules, ensuring separability, and simplifying packaging.

5. Communication

(i) We will disclose useful and reliable information to our shareholders, investors, co-workers, customers, partners, and local communities, not only as required by law, but also beyond that which we are required to disclose.

(ii) We will not conceal any improper matters from internal or external parties.

(iii) Employees are encouraged to report and consult with their superiors and colleagues immediately in the event of any misconduct or legal violations or any facts that may harm the company or society. If this is either not possible or cannot be resolved, please contact the Ryohin Keikaku Group Helpline. We will not tolerate any detriment a person might suffer as a result of reporting.

6. Information management

(i) We will take great caution in handling and protecting the personal information of our customers.

(ii) With regard to information such as intellectual property rights, know-how, and confidential business information, we shall comply with the relevant laws and regulations and rules, respect the rights of third parties, and, at the same time, strive to protect our own property.

The "Ryohin Keikaku Group Compliance Code of Conduct" has been established and is posted on our internal infrastructure as well as in a booklet distributed to directors, auditors, executive officers, and employees. The Group Compliance Code of Conduct is reviewed by the Board of Directors from time to time, and the decision of its revision or abolishment should be made after full discussion at meetings of the Board of Directors.

The Compliance and Risk Management Committee, which meets regularly, reviews the status of compliance with the Group Compliance Code of Conduct, investigates any violations, identifies the details and causes in the case of violations, and considers measures to prevent its recurrence. In addition, the Compliance and Risk Management Committee regularly verifies the effectiveness of the Group Compliance Code of Conduct.

In 2019, no significant non-compliance incidents in relation to the Group's business operations were recorded. We have also confirmed that no political contributions have been made. The number of non-compliance cases in FY2019 was eight. Concerning these cases, we notified the entire company of what has occured, and thoroughly educated the importance of compliance through internal training courses.

3 | Employee Hotline

The Ryohin Keikaku Group Helpline and the Customer Service Office have been established to provide business partners and general customers with a point of contact for anonymous reporting and consultation in the event of any violation of the Group Compliance Code of Conduct, any violation of laws and regulations, compliance violations (including anti-corruption), abuse of authority, sexual harassment, or any other inappropriate behavior by any officers or employees.

For inquiries from the general public, an inquiry platform has been set up on our website.

4 | Anti-corruption Measures

The Ryohin Keikaku Group has established anti-corruption regulations (*"Ryohin Keikaku Group Anti-Bribery Regulations, Anti-Bribery Guidelines") approved by the Board of Directors, which aim to prohibit bribery of public officials and ensure compliance with anti-corruption laws and regulations with regard to entertainment, gifts, invitations, donations, facilitation payments, insider trading, money laundering, embezzlement, obstruction of justice etc. Bribery is explicitly prohibited in these regulations. Entertainment, gifts, invitations, and donations are subject to the prior approval of the Compliance and Risk Management Committee chairman, who approves only those items he or she deems appropriate. In addition, the company's employment regulations prohibit corrupt practices by stipulating that employees shall not offer improper entertainment, lend or borrow money or goods, or give or receive money or goods improperly in the course of business.

The Audit Office conducts audits ensuring that the company's various anti-corruption measures are properly implemented, and, if any problems are found as a result of the audit, the Compliance and Risk Management Committee would consider countermeasures. If an anti-corruption violation is identified, it will be promptly reported to the Compliance and Risk Management Committee, which will then be the one to report to the Board of Directors, to discuss how to address the situation as well as how to improve the regulations themselves.

The Compliance and Risk Management Committee has created a risk management list to help each department recognize possible risks and understand how to respond to them. The risk management list corresponds to Ryohin Keikaku's operations manual, ensuring that information on specific responses and measures is made easily accessible. In addition, each department periodically reviews and updates the list on matters related to risks. The risk management list includes anti-bribery and anti-corruption items, which are then assessed and managed by each department as risks.

The Ryohin Keikaku Group's business partners pledge to comply with the Code of Conduct for Production Partners when doing business with Ryohin Keikaku. The Code of Conduct requires Ryohin Keikaku's business partners to maintain a sound and normal relationship with the political and governmental authorities, that is, not to engage in any form of bribery, corruption, racketeering, or embezzlement, and to put in place appropriate procedures to prevent bribery in all commercial transactions undertaken by Ryohin Keikaku's business partners. In addition, our company's business partners have pledged to accept our investigations to verify compliance with the Code of Conduct and to accept third-party factory audits (social audits) as part of Ryohin Keikaku's sustainability activities and to further take immediate corrective action and provide evidence of corrective action taken to Ryohin Keikaku if a violation of the Code of Conduct is determined. Business partners include all entities that do business with the company, such as factories, middlemen, and distributors.

The Ryohin Keikaku Group regularly holds training sessions for its employees in order to ensure that they are fully aware of the anti-corruption policies.

In FY2019, no employee was disciplined or dismissed for violations of Ryohin Keikaku's anti-corruption regulations or for violations of the regulations related to corruption as set forth in the employment regulations. In addition, Ryohin Keikaku has not paid any fines, penalties, or settlements in connection with corrupt practices.

5 | CoC for Business Partners