Malus and clawback

If it is determined that it is necessary to make revisions to financial statements because of an Executive Officer’s serious violation of laws and regulations or the Company’s internal rules, the Company shall take the following measures against the Executive Officer responsible for the situation (“Responsible Executive Officer”) whether it was done intentionally or unintentionally.

■Reduction and denial or forfeiture of compensation (malus)
The Company will reduce, deny, or forfeit all or part of the fixed remuneration and unvested incentive remuneration (bonuses, conventional stock options, and restricted stock-based remuneration) scheduled to be paid by the Company to the Responsible Executive Officer.

■Return of remuneration after lifting of transfer restrictions (clawback)
Of the vested incentive remuneration (bonuses, conventional stock options, and restricted stock-based remuneration) paid by the Company to the Responsible Executive Officer, the Company shall demand the return of the remuneration for the fiscal year in which the Board of Directors resolves that the Responsible Executive Officer’s conduct constitutes an event subject to the clawback provision and the three fiscal years immediately preceding that year, from the Responsible Executive Officer (including after their retirement) or their heirs.