Policy

Bribery Prevention Policy

1. Scope of Application

This Bribery Prevention Policy (this “Policy”) presents the basic principles that should be complied with by our directors, officers, employees and contract and dispatch employees (collectively, “All Executives and Employees”) in order for us to maintain appropriate relationships with public employees and our Business Partners (as defined below) in Japan and abroad and to perform business activities in a fair and ethical manner when we engage in corporate activities.

2. Basic Principles

We will comply with the laws and regulations and relevant restrictions (collectively, the “Laws and Regulations”) pertaining to the prevention of bribery and other corrupt practices (collectively, “Bribery”) applicable in countries and regions concerned, including the Penal Code, the Companies Act and the Unfair Competition Prevention Act of Japan, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, and shall thoroughly prevent acts of Bribery, any act of taking part therein, and any act that is likely to constitute such acts.

3. Prohibition of Bribery

Prohibition of Providing Bribes to Public Employees

All Executives and Employees shall neither directly nor indirectly engage in any act of bribery toward public employees, etc. in Japan and abroad, such as providing, or offering or promising to provide, money or other profits for the purpose of affecting the performance of or decisions on duties, such as the acquisition of licenses and approvals or other administrative procedures, in order to enjoy or maintain unfair business benefits.

Prohibition of Bribery with Business Partners

  • All Executives and Employees shall neither directly nor indirectly engage in any act of bribery toward civilians or private companies (collectively our “Business Partners”) in Japan and abroad that have a relationship with us, such as acts of providing, or offering or promising to provide, money or other profits for the purpose of affecting the performance of or decisions on duties in order to enjoy or maintain unfair business benefits.
  • All Executives and Employees shall neither directly nor indirectly engage in any act of bribery, such as soliciting, accepting or promising to accept money or other profits from our Business Partners in Japan and abroad, as a condition for implementing transactions or to acquire or maintain unfair business benefits.

Prohibition of Bribery Through Third Parties

All Executives and Employees shall not engage in any act of Bribery through a third party, such as a consultant or agency, and shall not tolerate any bribery by such third party.

Prohibition of Other Corrupt Practices, Etc.

All Executives and Employees shall not engage in or take part in concealing or falsifying any illegal source of funding, such as money laundering, or any other corrupt practices.

4. Management System

  • We will organize a system to cause All Executives and Employees to thoroughly comply with this Policy by placing an officer in charge who is responsible for preventing Bribery and establishing necessary internal rules.
  • We will make efforts to discover any violation or potential violation of this Policy at an early stage by performing transactions through appropriate approval procedures, etc. and carrying out necessary confirmations and subsequent reviews on the status of compliance with this Policy in each department under the instructions of the officer in charge.
  • We will accurately prepare accounting books and appropriately store relevant materials for all transactions. We will perform necessary confirmation to ensure that All Executives and Employees do not take part in concealing or falsifying any illegal source of funding when making payments to our Business Partners.
  • If we become aware of any potential violation of this Policy, we will conduct a strict internal examination and if we acknowledge the existence of any violation hereof by an officer or employee, etc., we will immediately rectify and take strict measures against such violation.
  • We will cooperate in good faith with the competent agencies if they inform us of the launch of any investigations or examinations in relation to Bribery.

5. Familiarization with and Education of this Policy

  • We will make efforts to ensure thorough compliance with this Policy by educating All Executives and Employees on a continuous basis.
  • We will make efforts to gain our Business Partners’ further understanding of this Policy by familiarizing them with this Policy and providing explanations thereon from time to time.