On March 1 2006, we, Deloitte Touche Tohmatsu-Japan (DTT Japan) has newly established "the Compliance Hotline" as the "contact window" to the public to accept whistlebrowing regarding ethics and compliance issues and/or potential violations of laws, regulations and other professional standards of partners and/or employees of our firm.

This Compliance Hotline is administrated by Anderson Mori Tomotsune Law Firm, a fully independent third party, to preserve confidentiality and, when requested, anonymity.

Any person who is not an employee of the DTT Japan can directly access the Compliance Hotline via our public website: www.deloitte.com/jp to report or blow the whistle to the designated attorneys at Anderson Mori Tomotsune Law Firm on ethics and compliance issues, violations of laws, ethical and/or other non-compliance activities that you believe are related to DTT Japan, 24-hours/day and 365-days/year from any location, under such circumstances:

• If you believe that ethics and compliance issues are not resolved, either through the existing managerial chain of command or other reporting alternatives.
• If you don’t feel comfortable reporting through the normal channels.
• If you would like to blow the whistle or report on ethics and compliance issues in a confidential way.
• If you wish to remain anonymous when reporting to DTT Japan.

Identity of the person accessed the Hotline and information provided by the person shall be treated confidential to the extent possible.  After receiving information regarding compliance issues, however, the designated attorneys at Anderson Mori Tomotsune Law Firm may provide information or submit a report to Compliance and Legal Department of DTT Japan in order to facilitate the investigation to resolve the issues, and shall start the research on the reported issues by themselves if they judged it as necessary. Notwithstanding the foregoing, the name of whistleblower is not reported to our firm, if such whistleblower desires to treat it as "confidential". 

Note

Examples of ethics and compliance issues and/or potential ethics violations include but not limited to:

• Participation in window dressing accounting
• Unlawful discrimination
• Harassment
• Workplace violence
• Substance abuse
• Conflict of interests
• Falsification of documents
• Inappropriate gifts and entertainment
• Inappropriate political activities and contributions
• Insider trading or securities law violation
• Breach of a client's or a DTT Japan entity's confidentiality
• Inappropriate disposal of a DTT Japan entity's documents
• Inappropriate use of a DTT Japan entity's resources
• Theft
• Bribe and kickback
• Inappropriate client billings
• Inappropriate reporting of time and expenses
• Other potential non-compliance with professional standards

* The purpose of this Compliance Hotline is not intended to give protection or to provide benefit to the whistleblower, and therefore, the designated attorney does not assume any obligation including replying to, or to investigating on behalf of the whistleblower. Further, the designated attorney does not provide any legal advisory services to such whistleblower.