Enactment January 01, 2026

‍

Chapter 1: General

Article 1. (Purpose)

1. These Regulations of Global Whistleblowing set out how illegal or inappropriate conduct within the Group should be reported. The purpose of these Regulations is to promptly detect, correct, and prevent misconduct, thereby ensuring strict compliance with laws and regulations and adherence to high ethical standards when engaging in business.
   
   For the purposes of these Regulations, the following terms shall have the meanings set forth below:
   
   “Company” means Monex Group, Inc.
   
   “Group” means the Company and its “affiliated companies” (kankei kaisha) as defined in Article 2 of the “Rules for the Management of Affiliated Companies” of the Company (excluding Coincheck Group N.V. (“CCG”) and its “subsidiaries” (ko gaisha) as defined in the same Article).
   
   “Group Company” means any company within the Group.
   
   “Relevant Group Company” means a Group Company that is or has been the subject of a report.
2. These Regulations apply only to reports submitted to a unified group-wide reporting channel designated by the Company (the "Global Hotline"). It does not apply to reports submitted to hotlines independently set-up by a Group Company, or to issues raised through regular reporting lines (e.g., reporting misconduct by an employee to his/her supervisor). For the avoidance of doubt, these Regulations of Global Whistleblowing acknowledge that: (a) CCG is a publicly traded company listed on Nasdaq with an independent audit committee under Nasdaq rules, and is otherwise operating under a governance structure, rules and best practices applicable to Nasdaq-listed companies and Dutch public limited liability companies, and its own articles of association, board regulations, committee charters and other polices adopted in connection therewith (collectively, the “CCG Governance Structure”); (b) the CCG Governance Structure includes its own duly adopted Whistleblower Policy; and (c) nothing herein shall be deemed to supersede or diminish the CCG Governance Structure, including its Whistleblower Policy.
3. Officers and Employees (as defined below) of Group Companies who are eligible to report under these Regulations are actively encouraged to use any reporting system available to them, including the Global Hotline, if they become aware of misconduct that has been or is about to be committed.

Article 2. (Scope of Reporter)

1. Individuals eligible to make a report to the Global Hotline under these Regulations ("Reporter") are the officers and employees of Group Companies, including all individuals engaged in the business of Group Companies, regardless of title or designation. “Employees” includes regular employees, contract employees, non-regular employees, part-time employees, temporary employees, and dispatched workers during their employment and within one year of retirement and completion of dispatch work. Collectively, these eligible persons are hereinafter referred to as “Officers and Employees”.

Article 3. (Matters to be Reported)

1. A Reporter may make a report to the Global Hotline regarding any act which violates or is likely to violate laws and regulations, or the Articles of Incorporation or internal rules or regulations of any Group Company committed by the Reporter or by other Officers and Employees of any Group Company ("Acts Involving Violation of Laws, etc."). Acts Involving Violation of Laws, etc. includes, but is not limited to, the following matters:
   
   (a) Bribery, violation of antitrust law;
   (b) Insider trading and other acts that violate securities-related regulatory laws and regulations;
   (c) Accounting and tax fraud;
   (d) Acts involving conflicts of interest;
   (e) Improper kickbacks;
   (f) Discrimination, harassment;
   (g) Embezzlement, fraud, theft, breach of trust;
   (h) Assault, threats;
   (i) Quality and inspection fraud;
   (j) Violation of laws and regulations related to the protection of personal information;
   (k) Violation of laws and regulations related to environmental protection, health and safety;
   (l) Leakage of company’s confidential information;
   (m) Forgery and alteration of contracts, reports and records;
   (n) Unauthorized use and destruction of company assets;
   (o) Retaliation against the Reporter and any other act in violation of these Regulations; and
   (p) Acts that violate international human rights standards and the Human Rights Policy of the Group.
2. In no circumstances may a Reporter knowingly make a false report. the Group.

Article 4. (Conflict with Local Laws and Regulations)

If these Regulations conflict with local laws and regulations that are mandatorily applicable to a Group Company, such local laws and regulations shall prevail over these Regulations.

‍

Chapter 2: Operation Method

Article 5. (Global Hotline)

1. The CEO of the Company (the “Legal Department”) designates the Global Hotline.
2. Reports may be made either anonymously or with the Reporter’s identity. [However, if a report is made anonymously, it may be difficult for investigators to contact the Reporter to obtain detailed information about the report, so it is recommended that the Reporter disclose his/her identity.]

Article 6. (Investigation)

1. When the Global Hotline receives a report, the head of the Legal Department (the “Head of Legal Department”) will promptly confirm receipt and notify the officer in charge of legal affairs of the Company (the “Global Hotline Representative”). Upon receiving the report, the Global Hotline Representative shall examine thoroughly the contents of the report and, if deemed necessary, investigate the case, either independently or by instructing an appropriate person within a Group Company (the “Investigator”), depending on the nature of the case. The Global Hotline Representative may, as necessary, consult with the Company’s CEO or a person designated by the Company’s CEO about the need for and method of investigation. However, if the Global Hotline Representative is the subject of or otherwise involved in the reported matter, any matters that are to be handled by the Global Hotline Representative under these Regulations shall instead be handled by a person designated by the Company’s CEO.
2. In conducting the investigation referred to in the preceding Paragraph, the Investigator may seek cooperation from the relevant departments and Officers and Employees of Group Companies, and, if necessary, entrust the investigation to external experts such as law firms or accounting firms. The relevant departments and Officers and Employees of Group Companies who are requested to cooperate in the investigation are obliged to cooperate. In such cases, the Global Hotline Representative may, to the extent permitted by applicable laws and regulations, share information about the investigation, including personal information, with the relevant departments and Officers and Employees of Group Companies or external experts in charge of the investigation.
3. In conducting the investigation described in this Article, individuals with any conflict of interest related to the reported matter shall not be involved in the investigation.

Article 7. (Report on Results of the Investigation, etc., Corrective and Preventive Measures)

1. The Investigator shall report the progress and results of the investigation to the Global Hotline Representative. The Global Hotline Representative shall report a summary of the results of the factual investigation to the Board of Directors of the Company.
2. If, as a result of the investigation, it is found that an Act Involving Violation of Laws, etc. has occurred or is likely to occur, the Global Hotline Representative shall notify the representative and audit committee or auditor of the Relevant Group Company (including persons in equivalent positions, but excluding any persons with a conflict of interest in relation to the reported matter) of the same. The Relevant Group Company shall promptly take corrective and preventive measures and any other actions deemed appropriate. The Global Hotline Representative may make observations and/or recommendations to the Relevant Group Company regarding such corrective and preventive measures or other actions.
3. If the Relevant Group Company decides to impose disciplinary action against the person involved in the Act Involving Violation of Laws, etc., in accordance with local laws and regulations and the employment rules or other internal rules of the Relevant Group Company, the Global Hotline Representative may still make observations and/or recommendations to the Relevant Group Company about such disciplinary action.
4. If the measures or actions under Paragraphs 2 and 3 of this Article are taken, the representative of the Relevant Group Company shall notify the Global Hotline Representative of the details. The Global Hotline Representative shall notify (in principle, within three months of the confirmation of receipt of the report) the Reporter of, to the extent that it does not interfere with an individual’s privacy or other rights and subject to confidentiality and legal requirements that may limit what can be disclosed to the Reporter, an outline of the investigation’s results and the corrective and preventive measures or other actions taken by the Relevant Group Company, as well as any disciplinary action taken by the Relevant Group Company.

Article 8. (Designation of Persons Engaged in Whistleblowing Disclosures)

1. The Company shall designate the Global Hotline Representative and the Head of Legal Department as “persons engaged in the activity of dealing with whistleblowing disclosures” under the Whistleblower Protection Act of Japan (Act No. 122 of June 18, 2004, as amended) (“Persons Engaged in Whistleblowing Disclosures”).
2. The Company may also, as necessary, designate Officers and Employees of Group Companies, and external experts as Persons Engaged in Whistleblowing Disclosures in the course of seeking cooperation on the investigations or formulation of corrective and preventive measures.
3. When designating Persons Engaged in Whistleblowing Disclosures, the Company shall comply with applicable local laws and regulations.

‍

Chapter 3: Prohibition of Retaliation and Confidentiality

Article 9. (Protection of Reporters and Cooperating Person)

1. A Group Company shall not treat a Reporter or any cooperating person adversely on the grounds that the Reporter made a report or the cooperating person cooperated on fact-finding relating to the report. Adverse treatment includes dismissal, termination, demotion, suspension of promotion, reduction of salary, warning, withholding or reduction of retirement benefits, unfavorable transfer, negative personnel evaluation, or harassment.
2. A Group Company shall take appropriate measures to ensure that the working environment of the Reporter and any cooperating person is not adversely affected due to their report or cooperation.
3. In the event that any retaliation has been found to have taken place, the Relevant Group Company shall consider and decide upon disciplinary action against the responsible person(s), and promptly implement it.

Article 10. (Confidentiality)

1. The Global Hotline Representative and the Head of Legal Department shall ensure the confidentiality of the reported content and other investigation-related information and shall handle with strict confidentiality any information that may identify the Reporter. Departments requested to cooperate under these Regulations and Officers and Employees involved in the tasks set out in these Regulations shall maintain the confidentiality of the reported content and the information obtained in the investigation.
2. Officers and Employees of Group Companies shall not try to obtain information which can identify the Reporter (regardless of whether a report is made anonymously or not), unless they have a justifiable reason to do so.
3. If a violation of this Article is identified, a Group Company shall consider and decide upon disciplinary action against the responsible person(s), and promptly implement it.

‍

Chapter 4: Miscellaneous

Article 11. (Revision of these Regulations, Preparation and Retention of Records, etc.)

1. The Company shall periodically review the contents of these Regulations and revise them as necessary.

2. The Global Hotline Representative shall periodically report to the Board of Directors of the Company on the maintenance, operation and other matters of the system under these Regulations, with due consideration for the protection of personal information and other sensitive data.

3. Persons engaged in the tasks set forth in these Regulations at Group Companies shall create records of the reported matters and contents, as well as information obtained during fact-finding investigations for the purpose specified in the preceding Paragraph and other purposes such as analyzing Acts Involving Violation of Laws, etc. and any necessary disclosures of the situation of utilization of the Global Hotline to external parties. However, unless otherwise required by applicable laws and regulations, any persons other than members of the Legal Department of the Company (the “Legal Department”) shall promptly delete such records after completion of the relevant tasks prescribed in these Regulations.

4. The Legal Department shall retain the records created pursuant to the preceding Paragraph for a period of three years, starting from April 1 of the fiscal year following the fiscal year in which the records were created. After the retention period has elapsed, statistical records shall be created, and the original records shall be deleted.

Article 12. (Dissemination and Educating on Officers and Employees)

The Company shall continuously provide information on an outline of these Regulations and the utilization of the Global Hotline to Officers and Employees of Group Companies to ensure that they can make full use of the Global Hotline.

‍

Chapter 5: Addendum

Article 13. (Responsible Department)

The Legal Department shall be responsible for these Regulations.

Article 14. (Amendment and Abolishment)

These Regulations may be amended or abolished by a resolution of the Board of Directors of the Company.

Article 15. (Procedures at a Group Company in connection with Enactment or Revision of these Regulations)

These Regulations shall be enacted or revised as mandatory regulations at each Group Company, following a resolution of the board of directors of such Group Company or through other procedures required under local laws and regulations applicable to such Group Company.