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.

Adopted June 1, 2015
Amended May 1, 2016