Coincheck Group N.V.

Code of Ethics

We have adopted a Code of Business Conduct and Ethics that applies to our all directors, officers

(including our principal executive officer, principal financial officer, principal accounting officer or controller or

persons performing similar functions) and employees of our corporate group, and to anyone to whom we have made

the code applicable by contract or otherwise. Our Code of Business Conduct and Ethics is posted to our website

(https://www.coincheckgroup.com/corporate-governance) and is a “code of ethics” as defined in Item 16.B of Form

20-F. We will make any legally required disclosures regarding amendments to, or waivers of, provisions of our Code

of Business Conduct and Ethics on our website.

Item 16.C