CORPORATE GOVERNANCE

Board & Corporate Auditors

  • Hae Jin Lee

    Chairman of the Board
  • Takeshi Idezawa

    Representative Director,
    President and
    Chief Executive Officer
  • Jungho Shin

    Director,
    Chief Service Officer
  • In Joon Hwang

    Director,
    Chief Financial Officer
  • Jun Masuda

    Director,
    Chief Strategy & Marketing Officer
  • Tadashi Kunihiro

    Outside Director
  • Koji Kotaka

    Outside Director
  • Rehito Hatoyama

    Outside Director
  • Hitoshi Kurasawa

    Corporate Auditor
  • Naoki Watanabe

    Corporate Auditor
  • Takashi Kanai

    Corporate Auditor

Corporate Governance Report


Articles of Incorporation

Chapter 1. General Rules
(Trade Name)
Article 1. The name of the Company shall be LINE KABUSHIKI KAISHA, and it shall be written in English as LINE Corporation.

(Purpose)
Article 2. The purpose of the company shall be to engage in the following business activities.
  1. Planning, design, development, operation, provision, and rental of software that utilizes telecommunication networks and electronic technologies
  2. All types of information collection and provision services that utilize telecommunication networks and electronic technologies
  3. Electronic communication business, Internet phone-calling and other telecommunication-related services
  4. Establishment of an Internet-based shopping mall
  5. Online shopping operations
  6. Planning, development, design, sales, rental, operation and the subcontracting thereof for e-commerce and e-payment services
  7. Planning, drafting, production and management of homepage or \ internet-based content
  8. Installation, retention, management, rental and leasing of communication devices, computers and other related equipment
  9. Planning, development and sales of computer systems and software
  10. Export, import, planning, development, and sales of game devices and software
  11. Design, retention, operation and management operations related to all types of information distribution systems that utilize electronic technologies
  12. Planning, development, production, sales, rental, retention, management operations and installation support for hardware and software related to telecommunication systems
  13. Design, manufacturing, sales, retention, management and intermediary of sales of telecommunication devices, information communication devices and other mobile devices, peripheral devices and computer network systems
  14. Design, development, and sales of computer hardware
  15. Provision of internet connection services
  16. Production, promotion and distribution of movies
  17. Planning, production, sales and rental of products with recorded music and film
  18. Planning, development, manufacturing, production, sales, rental, retention, management, operation and brokering thereof for character-licensed products, game devices, toys, other play-related products, mobile content and software
  19. Sales of snack foods and drinks, alcoholic beverages, clothing, electronic appliances, toys, stationery,cosmetics, watches, jewelry and daily sundries
  20. Event planning and operation
  21. Operation of restaurants, cafes and internet cafes
  22. Publishing business
  23. Planning and production of advertising and ad agency services
  24. Various marketing and research business
  25. Call center operations (outsourced landline calling and reception)
  1. Sales of used products
  2. Operation of cram schools
  3. Worker dispatch services, employment placement services, and research, counseling and training for vocational aptitude and capacity development
  4. Money lending, brokering and underwriting of loans, credit card handling, financial instruments business, bank agency services and other financial services
  5. Issuance, sales, management, operation of e-payment systems for e-money, other e-currencies, and other means of pre-payment and fund transfer operations
  6. Investment in relation to various businesses and the businesses related to company mergers, business alliances, transfer of businesses and securities, mediation and conciliation
  7. Operations related to damage insurance agency and life insurance solicitation
  8. Management and rental operations for real estate
  9. Following operations commissioned by other companies or organizations
    1. Planning, collection, creation, publishing and management of \ documents related to management analysis, business planning, statistics management and public relations
    2. Administer affairs related to bookkeeping, recording of revenues and expenditures, and settling of accounts
    3. Human resource, labor, benefit programs, education and training services for employees
  10. Management consulting for company management and subcontracting of management
  11. Acquisition, sales, usage licenses and other management operations for copyrights, design rights, trademark rights and industrial property rights
  12. Consulting or export and import operations related to any of the \ foregoing
  13. All businesses incidental to any of the foregoing

(Location of Head Office)
Article 3. The Company shall have its head office in Shinjuku-ku, Tokyo.

(Organs)
Article 4. In addition to a general meeting of shareholders and a Board of Directors, the Company shall have the following organs.
  1. Board of Directors
  2. Auditors
  3. Board of Auditors
  4. Accounting Auditors

(Method for Public Notices)
Article 5. The method of public notices of the Company shall be electronic public notices. However, if the Company is unable to issue an electronic public notice due to an accident or for any other unavoidable reason, public notices of the Company shall be issued in Nihon Keizai Shimbun.
Chapter 2. Shares
(Total Number of Issuable Shares)
Article 6. The total number of shares issuable by the Company shall be 690,000,000.

(Acquisition of Own Shares)
Article 7. Upon resolution by the Board of Directors, the Company shall be able to acquire its own shares via Market Transactions, in accordance with Article 165 Paragraph 2 of the Companies Act.

(Number of Shares Constituting One Unit of Share)
Article 8. The Number of shares constituting one unit of share shall be one hundred (100) shares.

(Rights with Respect to Shares Constituting Less Than One Unit)
Article 9. A shareholder may not exercise rights with respect to shares constituting less than one unit other than:
  1. Rights specified in each item of Article 189 Paragraph 2 of the Companies Act;
  2. Rights to demand acquisition per Article 166 Paragraph 1 of the Companies Act;
  3. A right to receive an allotment of subscription shares or subscription stock acquisition rights in accordance with the number of shares held by the shareholder; and
  4. A right to make the demand stipulated in the following article.

(Additional Purchase of Shares Constituting Less Than One Unit)
Article 10. In accordance with the provisions of the Share Handling Regulations, a shareholder holding Company shares constituting less than one unit shall be able to demand that the Company sell the necessary amount of shares which will, when added together with that shareholder’s existing shares, constitute one unit of share.

(Share Registrar)
Article 11. The Company shall appoint a share registrar.
2. The share registrar and its business office shall be determined by resolution of the Board of Directors.
3. Any business related to the shareholders register and the ledger of stock acquisition rights of the Company, shall be entrusted to the transfer agent and shall not be handled by the Company.

(Share Handling Regulations)
Article 12. Handling and fees related to shares of the Company shall be according to the Share Handling Regulations established by the Board of Directors.
Chapter 3. General Meeting of Shareholders
(Convocation)
Article 13. Regular general meetings of shareholders shall be convened within three months of the conclusion of each fiscal year, and extraordinary meetings of shareholders shall be convened when necessary.

(Record Date for Regular General Meeting of Shareholders)
Article 14. The record date for voting rights at a regular general meeting of shareholders shall be December 31 of every year.

(Convocator and Chairperson)
Article 15. Upon resolution by the Board of Directors, the President and CEO shall convene a general meeting of shareholders and act as the chairperson thereof, unless otherwise provided by laws and regulations. If that the President and CEO is unable to serve in this position, another Director, determined in accordance with an order of succession previously determined by resolution of the Board of Directors, shall act in place of the President and CEO.

(Disclosure via the Internet of Reference Documents for the General Meeting of Shareholders and the Deemed Provision of Information)
Article 16. In accordance with the ordinances of the Ministry of Justice, the Company shall be deemed to have provided shareholders with all necessary information stated or indicated in reference documents for the general meeting of shareholders, business reports, non-consolidated financial statements and consolidated financial statements, by disclosing such information via the Internet.
(Method for Adopting Resolutions)
Article 17. Except as otherwise provided by laws and regulations or by these Articles of Incorporation, all resolutions at general meetings of shareholders shall be passed by a majority of the votes of the shareholders in attendance entitled to exercise voting rights.
2. Special Resolutions provided for in Article 309 Paragraph 2 of the Companies Act may only be passed by two-thirds or more of the votes of the shareholders in attendance, who must hold in the aggregate a majority of the voting rights of shareholders entitled to exercise voting rights.

(Exercise of Voting Rights by Proxy)
Article 18. A shareholder may exercise his/her voting rights by authorizing one other shareholder with voting rights of the Company as his/her proxy.
2. The shareholder or his/her proxy in the preceding paragraph shall submit to the Company a document evidencing that authority of representation at each general meeting of shareholders
Chapter 4. Directors and Board of Directors
(Number of Directors)
Article 19. The number of Directors of the Company shall be no less than three and no more than eight.

(Election Method)
Article 20. Resolutions for the election of Directors shall be passed by a majority of the votes of shareholders in attendance, who must hold in the aggregate one-third or more of the total number of voting rights of shareholders entitled to exercise voting rights.
2. Resolutions for the election of Directors shall not be made by cumulative voting.

(Term of Office)
Article 21. The term of office of a Director shall expire upon conclusion of the last regular general meeting of shareholders of the final fiscal year ending within two years after his or her election.
2. The term of office of a Director elected to fill a vacancy or to increase the number of Directors shall be the same as the remaining term of office of the other Directors in office at that time.

(Convocator and Chairperson of Board of Directors)
Article 22. The President and CEO shall convene the meeting of the Board of Directors and act as the chairperson thereof, unless otherwise provided by laws and regulations. If the President and CEO is unable to serve in this position, another Director, determined in accordance with an order of succession previously determined by resolution of the Board of Directors, shall act in place of the President and CEO.
2. Notice of convocation of a meeting of the Board of Directors shall be sent to each Director and Auditor at least three days prior to the meeting. However, in the event of urgency, such period may be shortened.
3. When the consent of all Directors and Auditors is obtained, a meeting of the Board of Directors may be held without following the above procedures for convening a meeting.

(Representative Director)
Article 23. The Board of Directors shall appoint a Representative Director via resolution.
(Executive Directors)
Article 24. The Board of Directors shall appoint by resolution one Chairperson, one President, and may appoint one or more Vice Presidents, Senior Managing Directors, or Executive Directors from among its members.

(Resolutions of the Board of Directors)
Article 25. Resolutions of the Board of Directors shall be adopted by a majority vote of the Directors in attendance, who must constitute in number more than half the total number of Directors.
2. When requirements stipulated in Article 370 of the Companies Act are satisfied, resolutions of the Board of Directors shall be deemed to have been adopted.

(Regulations of the Board of Directors)
Article 26. In addition to laws, regulations and these Articles of Incorporation, matters related to the Board of Directors shall be governed by the Regulations of the Board of Directors established by the Board of Directors.

(Remuneration, Etc.)
Article 27. Remuneration, bonuses and other financial benefits to be received by Directors as consideration for the performance of their duties for the Company (“Remuneration, Etc.”) shall be decided by a resolution of the general meeting of shareholders.

(Exemption of Director Liability)
Article 28. In accordance with the provisions of Article 426 Paragraph 1 of the Companies Act, the Company may, upon resolution by the Board of Directors, exempt Directors (including former Directors) from liabilities for damage compensation stipulated in Article 423 Paragraph 1 of the Companies Act.
2. In accordance with the provisions of Article 427 Paragraph 1 of the Companies Act, the Company may enter into agreements with Directors (excluding Executive Directors, etc.) which limit their liabilities specified by Article 423 Paragraph 1 of the Companies Act. However, the liability limit amount under such agreements shall be the higher of either a predetermined amount of at least 10 million yen or the minimum liability amount provided for by laws and regulations.
Chapter 5. Auditors and Board of Auditors
(Number of Auditors)
Article 29. The number of Auditors of the Company shall be no more than five.

(Election Method)
Article 30. Resolutions for the election of Auditors shall be passed by a majority of the votes of shareholders in attendance, who must hold in the aggregate one-third or more of the total number of voting rights of shareholders entitled to exercise voting rights.
2. In accordance with the provisions of Article 329, Paragraph 3 of the Companies Act, the Company may elect Substitute Auditors at a general meeting of shareholders in order to prepare for any case in which the number of Auditors falls short of the number provided for by laws and regulations.
3. A resolution for the election of a Substitute Auditor described in the previous paragraph shall be effective until the commencement of the regular general meeting of shareholders to be held for the last fiscal year ending within four years after the resolution for the election, unless that term is shortened by a resolution of a general meeting of shareholders.

(Term of Office)
Article 31. The term of office of an Auditor shall expire upon conclusion of the last regular general meeting of shareholders of the final fiscal year ending within four years after his or her election.
2. The term of office of an Auditor elected to fill a vacancy of an Auditor who retires before the expiration of his or her term shall be the same as the remaining term of office of the retired Auditor whose vacancy he/she has filled. However, in the event that a Substitute Auditor described in the paragraph 2 of the previous Article assumes the office as an Auditor, the term of office of such Auditor shall not exceed the conclusion of the last regular general meeting of shareholders of the final fiscal year ending within four years after his or her election as substitute Auditor.

(Convocation of the Board of Auditors)
Article 32. Notice of convocation of a meeting of the Board of Auditors shall be sent to each Auditor at least three days prior to the meeting. However, in the event of urgency, such period may be shortened.
2. When the consent of all Auditors is obtained, a meeting of the Board of Directors may be held without following the above procedures for convening a meeting.
(Full-Time Auditors)
Article 33. The Board of Auditors shall appoint by its resolution one or more Full-time Auditors.

(Regulations of the Board of Auditors)
Article 34. In addition to laws, regulations and these Articles of Incorporation, matters related to the Board of Auditors shall be governed by the Regulations of the Board of Auditors established by the Board of Auditors.

(Remuneration, Etc.)
Article 35. Remuneration, Etc. for Auditors shall be decided by a resolution of the general meeting of shareholders.

(Exemption of Auditor Liability)
Article 36. In accordance with the provisions of Article 426 Paragraph 1 of the Companies Act, the Company may, upon resolution by the Board of Directors, exempt Auditors (including former Auditors) from liabilities for damage compensation stipulated in Article 423 Paragraph 1 of the Companies Act.
2. In accordance with the provisions of Article 427 Paragraph 1 of the Companies Act, the Company may enter into agreements with Auditors which limit their liabilities specified by Article 423 Paragraph 1 of the Companies Act. However, the liability limit amount under such agreements shall be the higher of either a predetermined amount of at least 10 million yen or the minimum liability amount provided for by laws and regulations.
Chapter 6. Accounting Auditors
(Election Method)
Article 37. Accounting Auditors shall be appointed at a general meeting of shareholders.
(Term of Office)
Article 38. The term of office of an Accounting Auditor shall expire upon conclusion of the last regular general meeting of shareholders held for the business year ending within 1 year after their election.
2. Unless a resolution to the contrary is adopted by the regular general meeting of shareholders described in the previous paragraph, the Accounting Auditor shall be deemed to have been reappointed.
Chapter 7. Accounts
(Business Year)
Article 39. The business year of the Company shall be one year commencing on January 1 of every year and ending on December 31 of the same year.

(Record Date for Distribution of Dividends from Surplus)
Article 40. The record date for distribution of dividends from surplus shall be December 31 of every year.
(Interim Dividends)
Article 41. The Company shall be able to, by resolution of the Board of Directors, pay interim dividends with June 30 of every year serving as the record date.

(Statute of Limitations on Dividends)
Article 42. In cases where dividends are paid in cash, the Company shall be relieved from the obligation of paying dividends if such dividends remain unreceived for three years after the date payment thereof commenced.
2. No interest shall accrue on unpaid dividends.
Chapter 8. Special Controlling Shareholders
(Special Controlling Shareholders)
Article 43. Special controlling shareholders stipulated in Article 179 Paragraph 1 of the Companies Act refers to those who hold 98 percent or
more of all voting rights granted by shares of the Company, in accordance with the stipulations of the same paragraph.
Revised April 1, 2017

LINE Group Code of Conduct

Preface
This Code of Conduct sets forth legal and ethical standards of conduct for employees, officers, directors, contract staff and external representatives and agents (“LINE Personnel” or “you”) of LINE Corporation, companies in which LINE Corporation directly or indirectly controls or holds the majority
of equity or shares, or other companies recognized by LINE Corporation’s Board of Directors to be a LINE Group company (collectively, the “LINE Group,” “LINE” or “we”).
1. LINE Group’s Mission
The LINE Group’s mission is to bring people, information and services closer together. It means that our activities are focused on 'Closing the distance,' between the various parties that use our services. We at LINE strive to bring cutting edge mobile technologies and design together to fulfill the universal human need for communication and beyond as we aim
not just to strengthen bonds between people, but forge new ties and connections, ultimately, bridging all kinds of information, services and goods together. We understand and will faithfully carry out this mission that will be the foundation for all of LINE Group’s businesses and the basis of each individual’s conduct.
2. Responsibilities to Society
2.1 Compliance with Laws
In carrying out LINE Group’s mission and to continuously grow and develop, it is critical that we comply with all applicable laws, regulations, ordinances and policies of the countries and regions (“Laws”) in which we operate in all of our business activities. LINE Personnel have a responsibility to understand and comply with all legal regulations applicable to their individual business duties. In addition, even when an action may not be in technical violation of any Laws, LINE's Personnel must understand that it is LINE policy that they must always act ethically.

2.2 Prohibition of Discrimination and Harassment, and Respect for Diversity
The LINE Group is expanding globally and is conducting business activities in countries and regions with varying cultures and ways of thinking. Understanding and respecting the diversity of these cultures and their way of thinking is a social as well as legal responsibility and will lead to
the greater advancement of our business. In order to create such a corporate culture, LINE will not condone or tolerate discrimination and harassment toward any LINE employee, user, or vendor based on their race, religion, gender, sexual orientation, nationality, social relations, or any other characteristic or status protected under national or local law. LINE will promptly address any reports of a violation of this policy. Retaliation against individuals making reports under this policy will not be tolerated.

2.3 Contributions to Society
As a member of a global society, the LINE Group supports disaster assistance, environmental protection, social welfare, education, art and cultural promotion activities, thereby contributing to the creation of more healthy and prosperous communities around the world. LINE Personnel are encouraged to take interest in these activities and actively support them.
3. Responsibilities to Shareholders
3.1 Insider Trading
During the normal execution of their duties, LINE Personnel may learn material non-public information regarding our or other companies’ earnings forecasts, new product announcements, restructuring, or other information that an investor may consider important in making a decision to buy or sell a security. However, the securities laws of various countries strictly prohibit attempts to use such information to buy or sell securities, or otherwise earn profits from such information, and the sharing of undisclosed material information with family members or others (including friends, users and other LINE Personnel), all of which constitute illegal insider trading (“Insider Trading”). LINE Personnel must not engage in Insider Trading or otherwise induce such activities, and must strictly follow any internal policies and guidelines that address insider trading.

3.2 Accuracy of Books and Records
The full, fair, accurate, timely, and understandable disclosure, including financial statements, in reports and other documents that are filed with or
submitted to relevant authorities and other public communications is important not only for compliance with tax, accounting, legal and other obligations, it also serves as the foundation of shareholder trust. Therefore LINE Personnel must ensure that LINE Group business records fairly and completely reflect our operations and financial condition. LINE Personnel should never intentionally delay recording transactions or events or intentionally record incorrect, incomplete or misleading information about any transaction or event.

3.3 Document Retention
LINE Personnel should follow all normal document retention Laws and internal policies as a general matter, but you must suspend normal document deletion practices if you receive instructions from the Legal Department concerning “document hold” orders. For example sometimes document retention procedures must be suspended to preserve documents for use in US litigation.
4. Responsibilities to Users
4.1 Privacy and Personal Information
As a provider of messaging and various other services, the LINE Group has been entrusted with the personal information of users around the world. These services are built on trust that is born from paying attention to the handling of personal information and appropriately protecting user privacy. It is LINE’s policy to comply with all Laws relating to the handling of personal information. In addition, LINE Personnel are responsible for ensuring that our services always only collect information necessary for achieving reasonable purposes, clearly inform users of the information collected and the reason for the collection, use the collected information only for said purpose, and delete user information when said purpose for which the information was collected has been achieved.

4.2 Improvement of Service Quality
The LINE Group’s services are used by users from diverse cultures, countries,
and demographics. In order to provide safe, secure and valuable services to a variety of users, we will respect the many diverse cultures of the markets where we conduct our business and commit to undertake maximum efforts to pursue quality services and products that enable true user satisfaction.

4.3 Fair Dealing and Responsible Marketing
LINE Personnel should endeavor to deal honestly with users and business partners. You must not misrepresent or conceal material facts.
LINE Personnel must adhere to the principles of fair marketing. For example, comparisons with, or references to, competitors or their services, must be done in a manner that is not deceptive or misleading, with care, and consistent with applicable Laws. Further, the LINE Group and its services should also be presented in a fair, complete, and accurate manner with care in all of its advertising and marketing materials.
5. Avoid Conflicts of Interest
5.1 Conflicts of Interest
A conflict of interest is when you have a personal relationship or financial or other interest that could interfere with your obligation to act solely in LINE’s best interests, or when you improperly use your position with LINE for personal gain. You must avoid allowing personal relationships or financial or other interests to interfere with your ability to act solely in LINE’s best interests or using your position for personal gain. If there is a conflict of interest (or if you are not sure if there is a conflict of interest) between the interests of LINE Personnel or their families and the interests of the LINE Group, you must immediately report the issue to HelpLINE, or elsewhere as directed by other policies.

5.2 Business Gifts, Entertainment, and Hospitality
Offering or accepting business gifts, entertainment, and hospitality can create the appearance of a conflict of interest. We will not seek, accept, offer, promise, or give (directly or indirectly) anything of value―including gifts, entertainment, or hospitality―from or to any person or firm as a condition or result of doing business with LINE. Regarding public officials, please refer to the related anti-bribery guidelines and also rule 6.2.

5.3 Protection and Proper Use of Company Assets
Improperly discarding or losing LINE Group assets (including information assets) can lead to serious damage to the company. Therefore, LINE
Personnel have a responsibility to carefully use LINE Group assets in conformity with the LINE Group Security Policy. In addition, LINE Group assets shall only be used for business activities, and shall not be used for personal or third-party profit or benefit.

5.4 Prevention of Trade Secret Disclosure
LINE Personnel shall, during and after employment, not disclose LINE Group trade secrets without LINE Group’s approval. Trade secrets may include not only classified information regarding the development of systems, services, know-how and technology, but also any other internal business materials that are not publicly available. LINE Personnel also shall not encourage a third party to use or disclose any third party’s trade secrets.

5.5 External Communications
LINE Personnel should not speak to the media, give speeches, present lectures, or otherwise speak on the LINE Group’s behalf without receiving advance approval from the Communications (PR) Department. Advance approval by the Communications Department is also needed for published materials like articles or books. You must also adhere to the LINE Group Employee External Communication Guidelines. For guidance on posting on social media, please refer to LINE Group Internet Posting Policy.
6. Thorough Compliance with Laws and Regulations
6.1 Compliance in the Work Environment
The LINE Group will comply with all Laws governing occupational safety and health and for the prevention of occupational accidents to promote a safe and productive working environment. Further, LINE Personnel must respect others, always communicate in a respectful and professional manner, and help build a corporate culture where discrimination and harassment are not tolerated.

6.2 Prohibition of Bribery
LINE is committed to maintaining high ethical and legal standards around the world. LINE prohibits bribery or corruption in any form, including giving, accepting, or authorizing bribes anywhere in the world. LINE Personnel may not provide or accept bribes or kickbacks, nor participate or cooperate in any direct or indirect corrupt practices involving government officials. In addition, depending on country or region, receiving and giving improper payments is considered bribery with civil and criminal liability. This prohibition also extends to third parties acting on LINE’s behalf, such as agents, representatives, contractors, or consultants. LINE Personnel must take care when selecting third parties to ensure that there is no indication that they might pay a bribe. To that end, LINE Personnel must comply with all related anti-bribery guidelines at all times.

6.3 Fair Competition and Antitrust Laws
Violations of antitrust and competition laws can lead to criminal and civil penalties for LINE and its employees personally, significant business disruptions, and harm to LINE’s reputation. LINE is committed to competing vigorously but fairly in all regions and countries in which it does business. Agreements with competitors present serious antitrust risks. Even seemingly well-intentioned communications about competitively sensitive subjects can raise concerns.
• Never enter into any understanding or agreement (whether formal or informal, express or implied) with any competitor to fix prices or, to divide users or geographic markets, or otherwise to agree not to compete.
• Avoid discussions with competitors about any competitively sensitive information (e.g., prices, costs, business strategies, users, market intelligence, etc.) without prior authorization from the Legal Department.
Consult with the Legal Department about restrictions on competition in any agreements with users or business partners, including any limits on the price at which a company can resell a LINE product.
6.4 Anti-Money Laundering
Money laundering is strictly prohibited by the law and the LINE Group. The LINE Group is committed to preventing money laundering and complying with all legal requirements and prohibitions relating to money laundering, including the filing of required reports with law enforcement and other authorities. You should always be vigilant in your dealings with trade partners, users, and employees in order to avoid engaging in or indirectly supporting anyone’s money laundering efforts. Potential signs of money laundering include large payments made in cash or by non-contracted parties, or payments from non-business accounts.

6.5 Intellectual Property
The LINE Group respects patents, copyrights, trademarks, trade secrets, and all other intellectual property rights. Therefore, in addition to aggressively striving to create and protect our own intellectual property, and before providing service, and products we must be wary not to infringe the intellectual property rights of others.
In addition, rights to all work-related inventions and creations by LINE Personnel shall belong solely to the LINE Group, except where expressly prohibited by law or where exceptions to this rule are clearly confirmed in writing by LINE.

6.6 Trade Controls (Sanctions, Export/ Import Controls, and Anti-boycott)
The laws and regulations of many countries prohibit or restrict business dealings with certain countries, companies, and individuals. For example, the United States has imposed comprehensive sanctions against certain countries, along with more limited sanctions against other countries. In addition, most nations maintain “Restricted Party” lists of individuals and companies with which trade is prohibited. Individuals and business entities on these lists are deemed to be involved in terrorist activities, unlawful exports, nuclear proliferation, drug or human trafficking, or other criminal actions, and any dealings with these parties may lead to heavy penalties. The LINE Group expressly prohibits any business or other dealings with any such Restricted Parties or with sanctioned countries, unless authorized by applicable law.
In addition, the LINE Group requires compliance with all export and import laws and regulations that apply to our international commercial activities, and, where applicable, with U.S. anti-boycott laws.
7. Reporting and Investigating Violations
7.1 Reporting and Prohibition of Retaliation
If you have concerns about violations of this Code of Conduct, you have a responsibility to promptly raise them with your supervisor, local HR Representative, the Legal Department, the Compliance Department, or the HelpLINE. All reports of misconduct are taken seriously and will be treated confidentially. If you feel more comfortable you may also use the whistleblower helpline to make report anonymously.
Retaliation against or harassment of any LINE Personnel who, in good faith, seeks advice, raises a concern, reports misconduct, or provides information in an investigation is against LINE Group policy and is strictly prohibited.

7.2 Investigating Code of Conduct Violations
LINE takes all reports of misconduct seriously. All reports of suspected violations will be taken seriously and will be promptly reviewed.
Appropriate investigators will be assigned to review all reported instances of violations of this Code of Conduct or applicable Laws. In accordance with applicable Laws, LINE strives to protect confidentiality of the identify of or information about the individuals involved, to the extent practical.

7.3 Disciplinary Actions
LINE Personnel are expected to follow all Laws while conducting business on behalf of LINE as a condition of employment. If you violate this Code of Conduct or applicable Laws, LINE will take appropriate disciplinary action, which may include:
• Disciplinary action, up to and including termination of employment; and
• In the case of criminal conduct or other serious violations of the law, notification to appropriate
governmental authorities will be made, and civil and/or criminal penalties may be imposed by a government or court.
8. Inquiries
Any questions, etc. concerning this Code of Conduct shall be submitted to
HelpLINE.
9. Administrative Procedures
9.1 Amendments to this Code of Conduct
Amendments to this Code of Conduct shall be approved by the LINE Corporation Board of Directors.

9.2 Waivers
Any exemptions from this Code of Conduct shall only be granted pursuant to express authorization under official internal governance procedures (in
the case of violations by executives, by Board of Director approval only).
Any such exemptions shall be appropriately disclosed in accordance with applicable laws.

9.3 Conflicts with Local Laws and Regulations
In the event that any part of this Code of Conduct conflicts with local laws or regulations, such conflicts should be reported to HelpLINE.

Versions other than Japanese and English can be found in the "About" section of our corporate site.

Adopted June 1, 2015
Amended May 1, 2016