Anti-Corruption Policy

Prohibition of bribery

Officers and employees are aware of laws and regulations related to bribery, fully understand that if they engage in bribery acts contrary to them, they may be punished not only for themselves but also for the entire company, and will not tolerate any form of bribery, and will ensure transparency in transactions and compliance with laws and regulations.

Entertainment, gifts, invitations, donations, etc. to bribery recipients

Officers and employees must obtain approval in accordance with internal regulations and rules when entertaining, gifting, inviting, donating, etc. to a person who is subject to bribery in accordance with the regulatory laws and regulations related to bribery.

Prohibited Matters

Officers and employees shall not use money, benefits, entertainment, gifts, etc., whether inside or outside the business to seek inappropriate benefits or conveniences from business partners.
When appointing an agent, etc., an officer or employee shall not instruct, induce, or assist the agent to bribe a person subject to bribery. In addition, the agency shall not bribe a person subject to bribery or pay a fee to the agency, etc. with the knowledge that it may be so.

Reporting and Approval

When providing or receiving entertainment, gifts, invitations, donations, etc., officers and employees shall obtain appropriate reporting including the amount, purpose, and recipient, and appropriate approval in accordance with the approval criteria.

Whistleblowing

Officers and employees may use the whistleblowing system when they become aware of a violation of these Bylaws or the possibility of such violations, and when it is recognized that no improvement is made even after reporting to their superiors.

Education System

The Company shall establish and implement a system for regularly providing education and training necessary for the prevention of bribery to officers and employees.

Audits, etc.

Internal Audit Office shall conduct regular audits in accordance with the Internal Audit Regulations to ensure that the Company's various anti-bribery measures are properly implemented.
As a result of the audit, review the rules and detailed rules as necessary, and instruct improvement measures.

Responding to violations

In the event of a violation of this policy, disciplinary action will be taken in accordance with the provisions of the internal regulations. In some cases, we will consider legal procedures.

Prohibition of Bribery

Officers and employees shall recognize the laws and regulations related to bribery and fully understand that engaging in acts of bribery may result not only in personal penalties but also in sanctions against the company as a whole. They shall not tolerate any form of bribery and shall ensure transparency in business transactions and strict compliance with laws and regulations.

Entertainment, Gifts, Invitations, and Donations to Bribery Targets

When providing entertainment, gifts, invitations, or donations to persons subject to anti-bribery regulations, officers and employees must obtain approval in accordance with internal regulations and procedures.

Prohibited Conduct

Officers and employees shall not, whether in the course of their duties or otherwise, engage in acts aimed at gaining improper benefits or preferential treatment from business partners by offering money, benefits, entertainment, gifts, or similar means.
When appointing agents or similar intermediaries, officers and employees must not instruct, induce, or assist them in committing acts of bribery toward persons subject to anti-bribery regulations. Furthermore, officers and employees must not pay commissions to such agents if they are aware that the agents are engaging in or are likely to engage in bribery.

Reporting and Approval

When providing or receiving entertainment, gifts, invitations, donations, or similar items, officers and employees must make appropriate reports, including the amount, purpose, and counterparty, and must obtain proper approval in accordance with established reporting and authorization standards.

Internal Reporting

If an officer or employee becomes aware of a violation or potential violation of this policy and finds that reporting the matter to a supervisor does not lead to improvement, they may use the company 's internal whistleblowing system.

Training Framework

The Company shall establish and implement a system to provide officers and employees with regular education and training necessary for the prevention of bribery.

Audits and Related Measures

The Internal Audit Office shall conduct regular audits based on internal audit regulations to verify that the Company's anti-bribery initiatives are being properly implemented.
Based on the results of these audits, revisions to regulations or rules and the issuance of corrective instructions shall be made as necessary.

Response to Violations

Any violation of this policy shall be subject to disciplinary action in accordance with internal regulations. Legal action may also be considered depending on the circumstances.