Article 1 (Purpose)
The purpose of this Policy is to promote the Company’s overall Anti-Corruption efforts in the spirit of fair play by clarifying the policy upon which all officers and employees of the Company (hereinafter referred to as “Offices and employees”) should base their Anti-Corruption efforts in accordance with the Charter of Corporate Conduct, and thereby to secure the trust of stakeholders and society in general.

Article 2 (Scope of application)
This Policy shall apply to all Officers and employees of the Company, regardless of the country or region where the Company operates.

Article 3 (Compliance with laws and regulations related to Anti-Corruption)
The Company shall comply with all Anti-Corruption laws and regulations in the countries and regions where the Company operates, including the Unfair Competition Prevention Law (Japan), the Foreign Corrupt Practices Act (US FCPA), the UK Bribery Act (UK UKBA), and Commercial Bribery Regulations (China) and other applicable international treaties.

Article 4 (Prohibition of bribery)
Except as permitted by related rules, officers and employees shall not offer, or promise to offer any money or other benefits, directly or indirectly, to “Public Officials,” to private customers, to suppliers, or to other business partners (hereinafter referred to as the “Business Partners, Etc.”) with the intent to defraud such person.
“Public Officials” includes below
  • Any official of any government or local government, domestic or foreign
  • Heads of state or any person exercising state power
  • Politicians and political party officials
  • Candidates for public office
  • Officials and employees of public international organizations
  • Officials and employees of corporations (including listed companies) owned or controlled by the government
  • Relatives, etc. of above


Officers and employees shall not direct bribery through third parties such as agents, consultants, distributors, or subcontractors, nor tolerate or condone such third parties giving bribery.

Article 5 (Prohibition of accepting bribery)
Officers and employees shall not directly or indirectly receive, demand or promise to receive any improper or unjustified benefits.

Article 6 (Thorough record-keeping and storage)
Officers and employees shall comply with procedures concerning financial reporting, accurately record all transactions in accounting books, and properly store relevant materials.

Article 7 (Lawful entertainment, gifts, etc.)


The Company shall appropriately manage entertainment, gifts, travel expenses, donations, support or sponsorship with Public Officials, and Business Partners, Etc. that are lawfully provided for legitimate business purposes, in accordance with the related rules and regulations.


The Company shall seek approval from the directors with respect to entertainment or gifts to Public Officials, political donations, and political funds, and shall operate with special care.

Article 8 (Audit)
The Company shall appropriately operate a system for conducting self-inspections and internal audits according to the degree of risk, regarding the status of compliance with this Policy and the internal rules established based on this Policy.

Article 9 (Structure and response)


In order to ensure compliance with this Policy, the Company shall establish internal reporting desks to which Officers and employees can report general compliance issues, including Aanti-Corruption.


In the event that any violation or potential violation of the relevant rules is discovered, the Company shall conduct a rigorous internal investigation and fully cooperate with any investigation by the relevant authorities, etc.


Officers and employees who violate related rules and regulations may be subject to personal liability and will be subject to strict disciplinary actions in accordance with the internal regulations of the Company to which they belong or their employment/delegation contract.

Article 10 (Revisions/abolition and management)
The revisions and abolition of this Policy shall be resolved and implemented by directors meeting.

Supplementary provision
This Policy shall be enforced from April 1, 2022.