Continuation of the Policy Regarding Large-Scale Purchase of Our Shares (Policy on Response to Takeovers)

Overview of the Response Policy

GMO Internet Group, Inc. has decided at the Board of Directors meeting on March 19, 2026, to continue the policy regarding large-scale purchase of our shares (takeover defense measures) introduced on March 13, 2006. This policy aims to maintain and enhance the common interests of shareholders and corporate value, stipulating obligations for large-scale purchasers to provide information, the Board of Directors’ setting of evaluation periods, and the implementation of countermeasures as necessary. The policy is effective from March 20, 2026 until the conclusion of the Board meeting following the 2027 Annual General Meeting of Shareholders.

Details of Large-Scale Purchase Rules and Countermeasures

Under the large-scale purchase rules, large-scale purchasers must provide detailed information prior to purchase actions, and the Board of Directors sets evaluation and consideration periods of 60 or 90 days. In cases of rule violations or significant impairment to corporate value, the Board may implement countermeasures such as free allocation of stock acquisition rights. To ensure the rationality and fairness of such countermeasures, an independent special committee consisting of outside directors and others is established. The framework also includes holding a shareholder meeting to confirm shareholder intent, allowing shareholders to determine the validity of countermeasures.