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ESG POLICY[ 01 ]

Spiral Capital Group ESG/Impact Investment Policy

Established on March 10, 2025

Spiral Capital Group uses the term “ESG” to describe the overarching ESG (Environmental, Social and Governance) matters that affect both the fund and the portfolio. In addition, Spiral Capital Japan Fund No. 3, which is managed by Spiral Capital, has established an impact investment policy and practices IMM (Impact Measurement and Management) in order to create environmental and social impact through investment in startups.

Environment Environment01

  • We will focus on solving environmental problems such as climate change. In particular, we will regularly measure the environmental impact of our group’s Scope 1 (direct greenhouse gas emissions), Scope 2 (indirect greenhouse gas emissions), and some Scope 3 (business travel, etc.).

Social Social02

    • Emphasis on addressing social issues such as diversity, equity, and inclusion (DEI), healthy work environments, and ethical and humane corporate practices (e.g., product design and supply chain).

    Governance Governance03

    • Emphasis will be placed on adherence to legal and regulatory requirements (e.g., the latest laws, regulations, and compliance standards), the development of appropriate governance structures (e.g., developing a code of conduct and adopting a whistleblower policy), and the implementation of data privacy and security measures.

    Impact Investing in the SCJF3 Fund04

    • With the goal of “promoting industrial reform in Japan and realizing a prosperous and sustainable society through startup investment and open innovation support,” we aim to create impact unicorns by investing in the following four ToCs.
    1. Environment: Contribution to environmental protection
    2. Wellness: Promoting physical and mental health
    3. Work Engagement: Improvement of job satisfaction in the work environment
    4. Diversity & Inclusion: Realization of a diverse society
    • IMM (Impact Measurement and Management) is practiced at the time of investment consideration and after investment execution, including periodic evaluation of impact KPIs and screening for negative impact.

    How ESG is managed in our VC funds

    ESG not only applies to the way we invest and help our portfolio companies prosper and grow, it is also part of the way we manage our funds internally. In order to continue our own progressive approach with respect to ESG, we manage our

    • All members of our firm take an ESG interest and think along ESG lines when making decisions and supporting our portfolio companies. Our ESG efforts are discussed regularly, at least once a year, at our partner meetings.
    • Spiral Capital became an official signatory to the United Nations Principles for Responsible Investment (UNPRI) in February 2023 and promotes activities in line with the six ESG principles.

    DEI POLICY[ 02 ]

    Spiral Capital Group DE&I Policy

    2025.3.31

    Background: Why We Value DE&I01

    Our firm recognizes that Diversity, Equity, and Inclusion (DE&I) play a crucial role in creating a sustainable society and are essential for corporate growth. As a member of the venture community, we are committed to fostering DE&I in all aspects of our operations.

    Our Goals for Advancing DE&I02

    To realize DE&I, our firm aims to promote the following initiatives:

    • Demonstrating and communicating DE&I through leadership
    • Fostering a psychologically safe and inclusive organizational culture
    • Recruiting and developing diverse talent
    • Ensuring transparency
    • Systemically addressing unconscious bias
    • Providing education and training on DE&I
    • Conducting regular evaluations and feedback

    Toward the Eradication of Harassment03

    Harassment is a serious human rights issue, and our firm absolutely does not tolerate any form of harassment against officers and employees within our firm or at our portfolio companies and prospective investee companies.

    To eradicate harassment, we will implement the following measures:

    • Establishing policies that do not tolerate harassment or any form of discrimination
    • Clearly demonstrating leadership’s commitment to eliminating harassment
    • Building a safe system for whistleblowing and reporting, and ensuring its fair operation
    • Providing education and training aimed at eliminating harassment and discrimination

    PRIVACY POLICY[ 03 ]

    Privacy Policy

    Established April 30, 2025

    Spiral Capital Corporation and Spiral Innovation Partners, Inc. (hereinafter referred to as “Spiral Capital”) recognize the importance of personal information obtained in the course of business operations and are committed to protecting such information. This Privacy Policy sets forth the Company’s policy on the protection of personal information handled by the Company as follows, and the Company has established an internal system to ensure that all employees are fully aware of this policy. In addition, matters not stipulated in this policy shall be in accordance with the provisions of the Personal Information Protection Law and other related laws and regulations.

    compliance with laws and regulations01

    We will comply with the Act on the Protection of Personal Information (the “Personal Information Protection Act”), guidelines issued by relevant ministries and agencies, and other relevant laws and regulations, and will handle personal information appropriately.

    acquisition of personal information and specification of purpose of use02

    We will acquire personal information to the extent necessary for our business by legal and proper means and specify the purpose of use as specifically as possible. When acquiring personal information, we will clearly state or publicly announce the purpose of use and will not use the information beyond the scope of the specified purpose of use without the consent of the individual.

    Restrictions on Use and Provision of Personal Information to Third Parties03

    We will use your personal information within the scope necessary to achieve the purpose of its use and will not provide it to any third party without your consent, except as required by law. We will not provide sensitive information or specified personal information (personal information including personal numbers) to any third party, except as required by law.

    purpose of use of personal information04

    The main purposes of use of personal information obtained and retained by the Company are as follows (individual notice or announcement may be given in each case).

    • Personal information regarding prospective investors (entrepreneurs and parties related to candidate companies): for research, contact, and contract negotiations for investment consideration and screening, as well as for operations necessary for our investment decisions.
    • Personal information regarding existing portfolio companies (related parties of portfolio companies): To support and monitor portfolio companies, provide management consultation, exercise rights as shareholders and investors, communicate with them, and perform related tasks.
    • Personal information regarding applicants for employment: To provide information regarding employment selection, interview contact, notification of results, and other recruitment activities, as well as information regarding future employment opportunities.
    • Personal information on company employees: for general employment management, including personnel and labor management, payroll and social insurance procedures, fulfillment of legal reporting obligations, provision of benefits, and internal communications
    • Identification documents for specific transactions: To confirm the identity of the customer in accordance with the Act on Prevention of Transfer of Criminal Proceeds, etc., and to confirm and respond to the exclusion of anti-social forces.
    • Personal information other than the above that we obtain in the course of our business: to respond to inquiries, to execute contracts, to provide guidance and information on our business, to prevent crime and security, and for other purposes specified at the time of acquisition.

    We will use personal information only to the extent necessary to achieve the purpose of use, and will obtain prior consent from the person in question when the need arises to use the information beyond the scope of the purpose of use.

    security control measures for personal information05

    In order to prevent leakage, loss, or damage of the personal data we handle, we take organizational, personnel, physical, and technical safety control measures to ensure the accuracy and confidentiality of personal information . Specifically, the Company will ensure that employees who handle personal data are appropriately authorized, that access control is implemented, and that safety management is carried out through fire and crime prevention measures, encryption, and other technical means. In addition, we will take measures to protect information systems that handle personal data from unauthorized access and malicious software.

    supervision of employees and contractors06

    We will provide education and training to all executives and employees on the importance of personal information protection and ensure that personal information is handled appropriately in their daily operations. When outsourcing the handling of personal data to an external contractor, we carefully select the contractor, stipulate necessary security control measures and confidentiality obligations in the contract, and regularly supervise and inspect the contractor. In the event of re-consignment, we will ensure the same thorough supervision.

    Response to Requests for Disclosure, etc. of Retained Personal Data07

    We will promptly respond to requests for notification of purpose of use, disclosure, correction, addition, deletion, suspension of use, elimination, suspension of provision to third parties, etc. (“disclosure, etc.”) regarding retained personal data in accordance with the provisions of the Personal Information Protection Law .

    contact for inquiries and complaints08

    Questions, comments, requests for disclosure, etc., or complaints regarding our handling of personal information may be directed to the following contact: . We will respond appropriately and promptly after confirming that the contact is from the person in question.

    continuous improvement09

    We will continuously review and improve our personal information protection system . We will review the contents of this Privacy Policy from time to time in response to amendments to laws and regulations, changes in social conditions, etc., and update it as necessary. The latest Privacy Policy will be posted on our website.

    ESG POLICY 01