Anti-corruption and anti-bribery policy

Maruho Hatsujyo Kogyo Co., Ltd. (hereinafter referred to as "the Company") considers corruption and bribery to be major obstacles to sustainable development which erode the social structure. Therefore, in our Charter of Corporate Behavior and Compliance Code of Conduct, we include "prohibition of offering to public officials, etc." and "fair trade, etc." as key pillars of our activities.

In addition, we are expanding the scope of our activities globally and developing our business in a fair, ethical, and lawful manner in a diverse international community. In the international community, OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions was enacted. Article 18 of the Unfair Competition Prevention Law (prohibition of the provision of illegal benefits to foreign public officials, etc.) in Japan, Foreign Corrupt Practices Law (FCPA, abbreviation of The Foreign Corrupt Practices Act) in the U.S. and the Anti-Bribery Law (Bribery Act), in the U.K. were enacted respectively. And major member countries have ratified the Convention and enacted and enforced their domestic laws.

In light of these global trends, we hereby declare our "Anti-corruption and anti-bribery policy."

Scope of application

This policy applies to the Company, its officers, employees, and temporary employees, as well as to all people (hereinafter referred to as "employees") who are engaged in the Company's business.

Our responsibilities

1. We will formulate and maintain rules on anti-corruption and anti-bribery that reflect the spirit and basic ideas of this policy, taking into account the social situation surrounding our company and the status of enforcement of laws and regulations concerning anti-corruption and anti-bribery.
   Corrupt conduct or bribery refers to the promise, offer, request or provision of valuables (including facilitation payment ※ regarded as a kind of bribe) or services that are directly or indirectly carried out in order to acquire, maintain or gain an unjust business advantage.
   * Payments to public officials etc. as an incentive to rapidly advance activities or processes.
2. We will establish and maintain a system to ensure that our policies against corruption and bribery are observed by our employees.

Declaration

1. We will not give, offer or promise to any public officer, deemed public officer, customer, business partner (hereinafter referred to as "public officer, etc.") or any individual or business organization any bribe, entertainment, etc., which may be corrupt or bribery, whether directly or indirectly, at home or abroad. We will not accept any bribes from public officials, individuals or business organizations.
2. We will maintain fair and sound relationships with all public officials, individuals and organizations in order to comply with all laws and regulations relating to anti-corruption and anti-bribery.
3. We will resolutely refuse any requests, demands, threats, harassment, or coercions made by public officials, individuals, or business organizations that require, threaten, harass, or coerce our employees to provide bribes, etc.
4. In order to confirm the rules and regulations of each organization and facility to which public officials belong and to comply with all laws and regulations concerning corruption and anti-bribery, we will not violate these rules and regulations.
5. To ensure thorough prevention of corruption and bribery, we regularly conduct employee training to ensure compliance and review our policies accordingly.

Representative Director and President  Kunihiro Iwase