Anti-Corruption Policy

The corporate philosophy of Rapidus and its subsidiaries (“Rapidus”) is to “contribute to the fulfillment, prosperity and happiness of people’s lives through semiconductors.” Business activities that are based on transparency and sincerity are indispensable in order to achieve this goal. Corrupt practices not only harm the trustworthiness of a company, but they also impede fair competition in the market and the healthy development of society as a whole. Misconduct for pursuing short-term profit ultimately obstructs the sustainable growth of a company, and it shakes the “prosperity and happiness of people,” which is Rapidus’ goal, to its core. Endeavors to prevent corruption will be an important pillar for companies and society to build a sustainable future together. Rapidus enacts the following Anti-Corruption Policy (this “Policy”) in order to fulfill its responsibility as a trustworthy company and contribute to the realization of a better society through ethical business. The details of this Policy will be reflected in the Rapidus Guidelines for Conduct and various policies and procedures.

Atsuyoshi Koike
CEO
Rapidus Corporation

1. Compliance with Laws and Regulations, etc.

   All officers and employees of Rapidus will comply with applicable laws and regulations of Japan and other relevant countries and regions, as well as internal rules concerning the prevention of corruption..

2. Applicable Scope

   This Policy applies to all officers and employees of Rapidus. Rapidus will also require its business partners and other related parties to support this Policy and put its items into practice, and it will promote the eradication of corrupt practices in cooperation with them.

3. Prohibited Acts

   1. All officers and employees of Rapidus will not give, or request or promise to give, directly or indirectly, money, goods, or other benefits to public officials, etc. (including officers and employees of companies owned or controlled by the government and other persons who are deemed to be public officials in that country; hereinafter “Public Officials, etc.”) or business partners, etc. (including candidates to be future business partners and other related parties; hereinafter “Business Partners, etc.”) for the purpose of inappropriately obtaining a benefit in the course of business. They will also not receive, or demand or be promised, money, goods, or other benefits from Public Officials, etc. or Business Partners, etc. for the same purpose.
   2. All officers and employees of Rapidus will not provide Public Officials, etc. with any unfair remuneration or reward, including facilitation payments, that are requested in order for administrative services to proceed smoothly.
   3. All officers and employees of Rapidus will not provide to Public Officials, etc. or Business Partners, etc., or receive from Public Officials, etc. or Business Partners, etc., any unfair money, gift, entertainment, or other benefit in excess of the scope that is found to be appropriate as a social convention. In addition, if doing so within the scope that is found to be appropriate as a social convention, they will do so upon going through the procedures prescribed in internal rules.

4. Organization to Prevent Corruption

   1. At Rapidus, endeavors to prevent corruption will be carried out by the Legal and Compliance Department with the Director in charge of Legal and Compliance as the person responsible.
   2. Rapidus will establish a point of contact for whistleblowing and operate it fairly and impartially in accordance with internal rules.
   3. All officers and employees of Rapidus will promptly consult with or report to the company if they discover an act that violates this Policy or that they suspect of doing so. Rapidus will also not permit any disadvantageous treatment or acts of retaliation against anyone who has had such a consultation or made such a report.

5. Treatment of Violations

   If any of its officers and employees have violated this Policy, Rapidus will strictly discipline them pursuant to the Regulation for Employment.

6. Education and Training

   Rapidus will continuously conduct education and training to all of its officers and employees that is necessary for them to put this Policy into practice.

This Policy was approved by the Board of Directors of Rapidus Corporation on February 20, 2025.