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 Officers 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 will 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 Officers and Employees will neither directly nor indirectly engage in any act of providing bribes 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 Officers and Employees will neither directly nor indirectly engage in any act of providing bribes toward civilians or private companies (collectively, “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 Officers and Employees will neither directly nor indirectly engage in any act of accepting bribes, 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 Officers and Employees will not engage in any act of Bribery through a third party, such as a consultant or agency, and will not tolerate any Bribery by such third party.
Prohibition of Other Corrupt Practices, Etc.
All Officers and Employees will 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 appoint an officer in charge who is responsible for preventing Bribery, and establish an appropriate system that enables each department to conduct appropriate approval procedures and subsequent review and detect any violation of this Policy or any possibility thereof at an early stage under such officer in charge.
5. Establishment of Rules to Prevent Bribery
- We will accurately prepare accounting books and appropriately keep relevant materials for all transactions. We will perform necessary confirmation to ensure that All Officers and Employees do not take part in concealing or falsifying any illegal source of funding when making payments to the Business Partners.
- If we become aware of any potential violation of this Policy, we will conduct a strict internal investigation. If any person among All Officers and Employees is confirmed to be in violation of this Policy, we will immediately rectify such violation and take strict measures regarding such matter.
- We will cooperate in good faith with the competent agencies if they notify us of their intention to conduct investigations or examinations in relation to Bribery.
6. Familiarization with and Education of this Policy
- We will make efforts to ensure thorough compliance with this Policy by educating All Officers 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.
