Results (December 2024 - November 2025) and Future Direction (December 2025 - November 2026) of AIN Group Compliance Promotion Action Plan (Formulated November 28, 2024)

We sincerely apologize again to all stakeholders, including our customers, business partners, shareholders and investors, for any inconvenience and concern caused due to the matter in which two people, a former officer of AIN HOLDINGS INC. (the “Company”) and a former officer of a subsidiary of the Company, were arrested on August 31, 2023 while employed at the companies, and subsequently indicted and convicted (the “Matter”). Based on cause analysis and recommendations for measures to prevent recurrence in the investigation report submitted on May 9, 2024 from the investigation team composed exclusively of external experts, we have formulated concrete measures to prevent recurrence and future initiatives regarding the Matter. On May 10, 2024, we opened a special page on our website to disclose the “state of initiatives under measures for the prevention of recurrence” taken up to that date, as well as the “initiatives planned for the fiscal year ending April 2025” and “for the strengthening of initiatives.” The disclosed initiatives have been implemented in the first half of the fiscal year ending April 2025. The Compliance Committee and the Board of Directors have discussed measures to further strengthen compliance and formulated the AIN Group Compliance Promotion Action Plan, and we disclose progress on a regular basis.

The AIN Group takes a broad and proactive view of compliance, not only in terms of compliance with laws, regulations, and internal rules but also as an “appropriate response to demands of society” on companies, including the practice of corporate ethics. We believe that if each officer and employee engages in compliance practices in this broader sense, it will lead to earning society’s trust and enable us to continue to realize our Group statement of “improving the health and happiness of our customers.”

The AIN Group has established the AIN Group’s Code of Conduct, which is shared by all officers and employees of the AIN Group, in order to incorporate compliance practices into concrete actions and maintain a sound corporate culture. The code explicitly sets out 14 items, including being mindful of conducting corporate activities in good faith and with ethics, always considering the perspectives of customers and patients while prioritizing meeting their expectations, and correctly understanding and complying with laws, regulations, and rules related to our business operations.
This Compliance Promotion Action Plan is formulated based on the AIN Group’s Code of Conduct with the aim of contributing to the sustainable growth of the AIN Group by widely disclosing specific actions and initiatives and reporting on their progress each fiscal year, maintaining their effectiveness, and constantly making regular checks and improvements.

December 1, 2024 - November 30, 2025

1. Dissemination of information by management and managers to firmly maintain our sound corporate culture 
   
   • Dissemination of messages from the top management that are focused on promoting compliance
   • Dissemination of information by management and managers other than top management (devise methods to encourage each employee to take ownership)
2. Establishment of a PDCA cycle that incorporates the perspectives of outside officers
   
   • Establishment of a governance process in which the Compliance Committee prepares proposals with advice from external experts and the Board of Directors scrutinizes the proposals
3. Enhancement of internal regulations, manuals, FAQs, etc.
   
   • Implement 2 and 5 of the initiatives planned for the fiscal year ending April 2025 (disclosed on May 10, 2024) in accordance with procedures
4. Enhancement of familiarization and training for officers and employees
   
   • Regularly hold training in the form of lectures, e-learning, and other means by appropriately stratifying officers and employees, including officers, sales-related staff, and all officers and employees
5. Making risk management more effective
   
   • Position and implement matters related to compliance in the Risk Management Committee’s initiatives as priority measures in the Action Plan
6. Appropriate operation of the whistleblowing system
   
   • Familiarize employees with the whistleblowing system, provide training to those involved in operation of the system, respond appropriately to individual incidences of whistleblowing, and regularly report to the Board of Directors
7. Strengthening of the internal audit function
   
   • Execute audits in accordance with the internal audit implementation plan for the fiscal year ending April 2025, including the development of internal audit processes for administrative departments

The “persons in charge of compliance with laws and regulations, etc.”  (AIN HOLDINGS division managers, department managers and the representative directors of affiliated companies), who are designated in the AIN Group’s Whistleblowing Regulations  as the persons in charge of implementing corrective measures relating to whistleblowing cases, will also be tasked with promoting the implementation of each measure in the Action Plan, according to their respective areas of responsibility.
The Compliance Committee will monitor the progress of the Action Plan as necessary and report to the Board of Directors, along with improvement proposals formulated with advice from external experts, and the Board of Directors will decide on the next action plan and continue its promotion.

• Dissemination of messages from the top management that are focused on promoting compliance
• Dissemination of information by management and managers other than top management (devise methods to encourage each employee to take ownership)

• We issued the messages from the top management in December 2024. The month of December, the beginning of the “AIN Group Compliance Promotion Action Plan”, is designated as “AIN Group Corporate Ethics Month”, and a message from the top management is planned to be delivered during this month every year.
• After determining the communication source, a project (the Philosophy Realization Promotion Project) was launched in May 2025 to review communication content. This project utilized the “Handbook” previously developed by PHARMACY Co. Ltd., the Group company, before its integration into the Group, and advanced discussions to expand it into a new common document for group-wide communication materials. Additionally, discussions progressed to revise the “AIN Group’s Code of Conduct”. The new common document will be positioned as a “Code of Conduct Guidelines,” designed to clearly and effectively communicate the principles for daily actions, based on the “Group Statement” and the “AIN Group’s Code of Conduct.” We are currently considering operational methods for its release starting with the “AIN Group Corporate Ethics Month” in December, at the beginning of the next planning period.

• Continuation
  Dissemination of messages from the top management in December
• Improvement
  Establish a system for disseminating information through group work and other means, and consider implementation at the store level.

• Establishment of a governance process in which the Compliance Committee prepares proposals with advice from external experts and the Board of Directors scrutinizes the proposals

• With advice from external experts, we established and implemented a PDCA cycle (as follows) to scrutinize the action plan for December 2024 to November 2025 at the Board of Directors meeting.

1.  The Compliance Committee Secretariat formulated an annual action timetable and reports on the status of each priority measure at regular meeting (every two weeks) with external experts（law firm）, and promotes initiatives while seeking improvements based on advice received.
2.  After organizing the content at the Compliance Committee meeting

   held in May, report the first-half results and second-half outlook at the regular Board of Directors meeting.

3.   Based on the points raised at the Board of Directors meeting, we will continue the process outlined in 1 above with necessary improvements, advance initiatives for the second half of the year, and formulate a draft plan for the next year.
4.  At the Compliance Committee meeting held in November, the content was organized, and a pre-briefing session was held for outside officers. Subsequently, at the regular Board of Directors meeting, the annual results were reported and the action plan for the next term was formulated.

• Improvement
  While continuing established processes, we aim to deepen the contents.

• Implement 2 and 5 of the initiatives planned for the fiscal year ending April 2025 (disclosed on May 10, 2024) in accordance with procedures　

• By May 2025, in preparation for the initiatives planned for the fiscal year ending April 2025 (disclosed on May 10, 2024), specifically items 2 (creation of internal regulations regarding matters such as fair competition, prohibition of acts that may impede the fairness of auctions, bidding, etc.) and 5 (enhancement of the Anti-Bribery and Anti-Corruption Policy by providing a manual and FAQ on the concept of civil servant and other relevant matters with concrete examples, etc.), we implemented "measures to improve the comprehensiveness and completeness of internal regulations and rules to facilitate their management," as well as "measures to strengthen our human resources." Subsequently, in the second half of the year, we made partial revisions to the AIN Group  Anti-Bribery and Anti-Corruption Policy at the Board of Directors meeting in October 2025. Additionally, we added information on the concept of civil servant and other relevant matters to the "Sales Activities Pocket Manual," with plans to distribute it to sales personnel by November of the same year.

• Continuation
  Plans to establish guidelines for the Anti-Bribery and Anti-Corruption Policy, among other measures

• Regularly hold training in the form of lectures, e-learning, and other means by appropriately stratifying officers and employees, including officers, sales-related staff, and all officers and employees

• The following was implemented:
  Training for Group Officers (July 2025), Training for Group Sales Representatives and Others ^*(March 2025), e-learning for all Group Officers and Employees (March to May 2025).

^*The 1st session was conducted in October 2024

• Continuation
  Implement awareness campaigns and training for each target group

• Position and implement matters related to compliance in the Risk Management Committee’s initiatives as priority measures in the Action Plan

• Of the “Major Risks” and “Risks requiring countermeasures” in the fiscal 2025 Risk Management Plan finalized by the Risk Management Committee, 11 compliance-related items have been positioned as priority measures in this action plan and are currently being promoted. Progress management is conducted by the Risk Management Committee (scheduled for April 2025 and October 2025 during this plan period).

• Transfer and Continuation
  Implemented by the Risk Management Committee

• Familiarize employees with the whistleblowing system, provide training to those involved in operation of the system, respond appropriately to individual incidences of whistleblowing, and regularly report to the Board of Directors

• Continue implementing the annual routine of informing employees about the whistleblowing system and conducting awareness surveys (during this plan period, employee notification about the whistleblowing system was conducted in December 2024, and the awareness survey was conducted in June 2025).
• Conduct group training for investigators handling individual whistleblower cases in November 2025 to improve the appropriateness of responses to such cases, and implement regular reporting to the Board of Directors (twice annually; during this plan period, in May 2025 and November 2025).

• Continuation
  Implement employee awareness, training, response measures, and reporting to the Board of Directors.

• Execute audits in accordance with the internal audit implementation plan for the fiscal year ending April 2025, including the development of internal audit processes for administrative departments

• Conducted audits in accordance with the Internal Audit Implementation Plan and advanced the Internal Audit Co-Source and Enhancement Project with support from external consultants. For the fiscal year ending April 2026, we continue to advance the project in accordance with the internal audit implementation plan approved by the Board of Directors.

• Transfer and Continuation
  Based on initiatives from the previous term, the Corporate Audit Office will sequentially conduct headquarters audits.

The AIN Group has established the "AIN Group's Code of Conduct,” which is shared by all officers and employees of the AIN Group, in order to incorporate compliance practices into concrete actions and maintain a sound corporate culture. It is codified in four sections: “Interactions with People,” “Interactions with Business Partners,” “Interactions with Shareholders,” and “Interactions with Society.” This Compliance Promotion Action Plan is formulated with the AIN Group Code of Conduct as its foundation with the aim of contributing to the sustainable growth of the AIN Group by widely disclosing specific actions and initiatives and reporting on their progress each fiscal year, maintaining their effectiveness, and constantly making regular checks and improvements.

December 1, 2025 - November 30, 2026

1. Dissemination of information by management and managers to firmly maintain our sound corporate culture 
   
   • Dissemination of messages from the top management that are focused on promoting compliance
   • Dissemination of information by management and managers other than top management (devise methods to encourage each employee to take ownership)
2. Fulfillment of a PDCA cycle that incorporates the perspectives of outside officers
   
   • Fulfillment of a governance process in which the Compliance Committee prepares proposals with advice from external experts and the Board of Directors scrutinizes the proposals
3. Enhancement of internal regulations, manuals, FAQs, etc.
   
   • Development of guidelines and other measures related to Anti-Bribery and Anti-Corruption Policy
   • Appropriately address findings identified during headquarters audits conducted sequentially by the Corporate Audit Office
4. Enhancement of familiarization and training for officers and employees
   
   • Regularly hold training in the form of lectures, e-learning, and other means by appropriately stratifying officers and employees, including officers, sales-related staff, and all officers and employees
5. Appropriate operation of the whistleblowing system
   
   • Familiarize employees with the whistleblowing system, provide training to those involved in operation of the system, respond appropriately to individual incidences of whistleblowing, and regularly report to the Board of Directors

(Previous plan 's “5. Making risk management more effective” and “7. Strengthening of the internal audit function” will be transferred to the Risk Management Committee and the Corporate Audit Office, respectively, for continued implementation and will not be included in this plan.)

The “persons in charge of compliance with laws and regulations, etc.”  (AIN HOLDINGS division managers, department managers and the representative directors of affiliated companies), who are designated in the AIN Group’s Whistleblowing Regulations  as the persons in charge of implementing corrective measures relating to whistleblowing cases, will also be tasked with promoting the implementation of each measure in the Action Plan, according to their respective areas of responsibility.
The Compliance Committee will monitor the progress of the Action Plan as necessary and report to the Board of Directors, along with improvement proposals formulated with advice from external experts, and the Board of Directors will decide on the next action plan and continue its promotion.