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Article 1 (Objective)

Considering the recent worldwide trend to strengthen anti-corruption regulations, this is to specify more concrete standards, etc. regarding the provision of Article 5 (Relationship with outside persons) of the Compliance Guidelines. Also, the current general trend is that companies are required to obtain the understanding of business partners concerned by making own anti-corruption policy public. Based on the trends aforementioned, we hereby publish our anti-corruption policy externally to request our business partners' understanding and cooperation, as well as to ensure internally widespread awareness of all of our directors, officers and employees, for achieving thorough compliance with anti-corruption regulations in accordance with this policy.

Article 2 (Maintenance of sound and normal relationship with public official or person in a similar position (see Appendix 1), Prohibition of bribing and of being bribed)

• We prohibit that all of our directors, officers and employees offer, promise or give, directly or indirectly through a third party, irrespective of whether at home or abroad, for the purpose of obtaining or retaining business or an advantage in the conduct of business for our company (see Appendix 2), any money or other financial advantage or anything of value (see Appendix 3) to a public official or employee of a public organization, or any person similar thereto (hereinafter referred to as a “Public Official, etc.”) intending to influence any act of such Public Official, etc., in his or her official capacity, or authorize any of the aforementioned acts.
• In principle, any planned entertainment of a Public Official, etc., shall be reviewed and approved in advance by the Compliance Supervising Officer. The Compliance Supervising Officer must confirm that the planned entertainment is within the range of accepted social courtesies, taking into consideration various factors, such as a nation state involved, industry characteristics, amount of expenses, content of entertainment, frequency, relationship with counterpart to be entertained, timing of the entertainment, etc. , does not violate any applicable anti-corruption laws or regulations, and does not appear to have been proposed for the purpose of obtaining an unfair advantage in business dealings. And the Compliance Supervising Officer must obligate all directors, officers and employees to prepare a report confirming that the entertainment was conducted as approved by the Compliance Supervising Officer after the entertainment in a timely manner, and to keep an accurate record of expenses of such entertainment. In principle, the Audit & Supervisory Board Member shall review the operation of the rules on the entertainment of a Public Official, etc., once a year.

Article 3 (Maintenance of sound and normal relationship with any person concerned other than a Public Official, etc. Prohibition of bribing and of being bribed)

All of our directors, officers and employees must not offer, promise or give to any person concerned other than a Public Official, etc., directly or indirectly through a third party, irrespective of whether at home or abroad, for the purpose of obtaining or retaining business or an advantage in the conduct of business for our company (see Appendix 2), any money or other financial advantage or anything of value (see Appendix 3). In principle, the provisions in the preceding article shall apply mutatis mutandis to the entertainment of any person concerned other than a Public Official, etc.

[Appendix 1] Definition of a “Public Official, etc.”

• Any member of an assembly or committee or any other person (including any person serving for the Embassy) who engages in public services for a nation state, government, or local public entities (hereinafter referred to as the "government, etc.") and its candidate.
• Any officer and employee of a political party who holds effective public authority.
• Any person who engages in services for an organization constituted under special public laws to carry out specific tasks concerning public interest. (for example, any official or person of a public organization, such as the Bank of Japan, etc.)
• Any person who engages in services for an enterprise in which the government, etc. exercises strong influence in any of the following forms, (hereinafter referred to as an "employee of public enterprise, etc."), as mentioned below.
  
  1. Any enterprise in which a majority of its voting shares are owned by the government, etc.
  2. Any enterprise in which a majority of its total capital is contributed by the government, etc.
  3. Any enterprise in which a majority of its officers (directors, board members) are designated or appointed by the government, etc.
  4. Any enterprise in which a majority of the voting rights of all shareholders are owned by the government, etc.
  5. Any enterprise which holds the power in order that all or part of the resolutions of general shareholders' meetings cannot be effective, or such resolutions can be invalidated, in the cases where the government, etc. does not give permission, approval, license, consent, or other similar acts to such resolutions.
  6. Any enterprise which is under the control of any other enterprise which is directly controlled by one or more national or foreign governments, etc.
• Any person who engages in public services for an International Organization (United Nations, etc.)
• Any person who exercises a public function on behalf of the government, etc. or an international organization as delegated. (Official and staff of a designated inspection agency or designated testing agency of the government, etc. or the international organization)

[Appendix 2] Examples of acts of “obtaining or retaining business or an advantage in the conduct of business”:

• Obtaining commercial transactions
• Obtaining a favorable evaluation or reputation
• Obtaining confidential information
• Requesting not to disclose misconduct or scandals

Etc.

[Appendix 3] Examples of “any money or other financial advantage or anything of value”

• Money, cash vouchers, gift cards, gift coupons, unlisted shares, loans, mortgages and guarantees
• Gift, entertainment and invitations (watching a sports game, theater and tours, etc.)
• Donations, contributions, etc.
• Gratuities, rebates, promotional fees and discounts
• Access or favors to job opportunities, education or medical care, etc.

Etc.

Establishment: 28 February, 2018