The Daiwabo Group* shall comply with laws, regulations, and social ethics, and prohibit all corrupt practices such as bribery, conflict of interest, embezzlement, fraud, coercion of benefits, rigged bidding, and other practice which constitute an abuse of one’s own or a third party’s professional rights or status, and shall also work to prevent corrupt practices amongst the Daiwabo Group’s business partners and others.

 

*       “The Daiwabo Group” refers collectively to Daiwabo Holdings Co., Ltd. and its consolidated subsidiaries.

 

1.    Compliance with laws and regulations

The Daiwabo Group shall conduct its corporate activities in compliance with the Unfair Competition Prevention Act, the Anti-monopoly Act, and other laws and regulations of the relevant countries related to the prevention of corrupt practices such as bribery, as well as this policy and the Daiwabo Group Corporate Code of Conduct.

 

2.    Prohibited activities

The Daiwabo Group shall not engage in any corrupt practices, including bribery, towards public officials and all stakeholders involved in the Group’s business, whether directly or indirectly, both domestically and overseas.

In addition, the Daiwabo Group prohibits the provision or receipt of inappropriate financial benefits, such as money, gifts, or entertainment that exceed the scope of what is considered appropriate according to social customs.

 

3.    Management system

The Daiwabo Group shall appropriately establish mechanisms such as internal rules to prevent corrupt practices in accordance with laws and regulations, and shall regularly check the compliance status and effectiveness of such rules and implement the necessary measures, such as reviewing internal rules, depending on the results.

 

4.    Education and training

To ensure compliance with this policy, the Daiwabo Group shall regularly provide its officers and employees with education and training on anti-corruption matters, such as the prohibition of bribery and awareness of the internal reporting system.

 

5.    Proper accounting and record keeping

In order to fulfill its accountability for compliance with this policy, the Daiwabo Group shall, under an appropriate internal control system, accurately record items such as expenditure approval documents and accounting ledgers based on the facts, and properly store the related documents.

 

6.    Reporting, Investigation, and Disposition

The Daiwabo Group shall establish a system for superiors, the compliance management department, and others to receive reports or whistle-blowing on corrupt or potentially corrupt activities from officers and employees. In addition, we shall also thoroughly protect officers and employees who have provided reports or whistleblowing to ensure that they do not suffer any disadvantage.

If the Daiwabo Group discovers any conduct that violates or may violate items such as laws, regulations, or this Policy, it shall promptly conduct an investigation and take disciplinary action against any officers or employees found to be in violation of said items.

If any such violation is discovered, it shall be reported to the Board of Directors in accordance with the basic policy regarding the internal control system.

 

Date of enactment April 30, 2024

 

Daiwabo Holdings Co., Ltd.

Representative Director, President and Chief Executive Officer

Chair of the ESG Promotion Committee

Yukihiro Nishimura