Customer Harassment Policy

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Ark Mori Building 31st floor, 1-12-32 Akasaka, Minato-ku, Tokyo
Capital Servicing Co., Ltd.
Representative Director Daniel Shireman

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1.Basic Policy on Responding to Customer Harassment

The Company strives to provide greater customer satisfaction by responding sincerely to customers and meeting their expectations while honoring their trust. In rare cases, however, customer demands, statements, oractions may involve statements or actions that denigrate employees’ character,violence, or other seriously disruptive conduct that undermines employees’ dignity and harms their work environment.

The Company respects the human rights of its employees and will take a firm, organization-wide approach to addressing customer harassment to ensure a safe and secure working environment in which employees can perform their duties with peace of mind. The Company establishes this policy to build and maintain sound and positive relationships with customers.

2.Definition of Customer Harassment

The Company defines customer harassment as “communications, demands, statements, or actions by customers directed at the Company’s employees that constitute seriously disruptive conduct exceeding the bounds of what is generally considered socially acceptable and that harm or may harm the working environment of the Company’s employees.”

The following are examples of conduct that may constitute customer harassment. These examples are illustrative and are not exhaustive.

• Acts of violence
• Verbal abuse, insults, slander, or defamation
• Intimidation or threats
• Remarks that denigrate an employee’s character, or discriminatory remarks
• Forcing employees to prostrate themselves in apology or to apologize in other unreasonable ways
• Compelling employees to remain engaged for prolonged periods orpersistently contacting them, including by telephone
• Forcing employees to respond in ways that exceed the bounds of what is generally considered socially acceptable
• Unjustified or excessive demands that lack a reasonable basis
• Posting content that damages the reputation of the Company or itsemployees, or personal information, on social media or similar platforms
• Sexual harassment, sexual orientation and gender identity harassment, stalking, or other forms of harassment directed at employees

3.Response to Customer Harassment

The Company will seek to resolve matters raised by customers,including communications and demands, through reasonable and rational discussion. However, if the Company determines that the conduct constitutes customer harassment, it may discontinue the interaction, decline to provide regular customer service thereafter, or consider appropriate legal measures as necessary.

In cases deemed particularly egregious, the Company will respond firmly in cooperation with the police, attorneys, and other external experts, giving the highest priority to ensuring employee safety.

4.Initiatives to Prevent Customer Harassment

·        Through this policy, the Company will clarifyits basic stance, communicate it to employees, and raise their awareness.

·        The Company will establish methods and procedures for responding to customer harassment.

·        The Company will provide employees with education and training on customer harassment and how to respond to it.

·        The Company will establish a consultation desk for matters relating to customer harassment and a framework for coordinating with the police, attorneys, and other external experts as necessary.

·        The Company will protect the privacy ofindividuals seeking consultation and other persons concerned, and will inform employees that no one will be subjected to adverse treatment for seeking consultation or taking similar steps.

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