Anti-bribery Policy of KAMEDA SEIKA Group

We, KAMEDA SEIKA Group (this term refers to KAMEDA SEIKA CO., LTD. as well as its subsidiaries and affiliates in various countries in the world; this applies hereafter), represent in our code of conduct that we shall comply with the laws and regulations in the course of our business activities, prohibit provision of unfair profits or benefits to any particular person(s), and perform fair and sincere transactions.
Considering that enhanced prevention of bribery is desired in the global trends, KAMEDA SEIKA Group hereby establishes this policy so as to further promote its approach with its code of conduct above.
KAMEDA SEIKA Group shall make efforts to prevent bribery on the basis of this policy so that we can further maintain and develop the trust from the people in the society in Japan and in all other countries and areas where group companies are doing business.

1. Compliance with Laws and Regulations

KAMEDA SEIKA Group and its officers and employees shall comply with the laws and regulations related to bribery prevention and applied to them in any countries or areas.

2. Prohibition of Bribery to Public Officials

KAMEDA SEIKA Group or its officers or employees shall not, directly or indirectly, give or promise to give money or other profits to public officials in or out of Japan with an intention to have them perform or omit their duties in order to ensure or maintain the group’s business benefits.

3. Prohibition of Bribery to Other Entrepreneurs

KAMEDA SEIKA Group or its officers or employees shall not take any of the following actions to other entrepreneurs in or out of Japan.

(1) Giving bribes
To directly or indirectly give or promise to give money or other profits to other entrepreneurs in or out of Japan with an intention to have them perform or omit their duties in order to ensure or maintain the group’s business benefits
(2) Accepting bribes
To demand other entrepreneur to give, promise to accept or accept money or other profits in or out of Japan in order to ensure or maintain the group’s business benefits

4. Action toward a Third Party

Provisions 2. and 3. shall also apply to the actions taken by a third party (distributor, consultant, agent etc.) to which KAMEDA SEIKA Group outsources its business.

5. Thorough Control of Accounting Records

KAMEDA SEIKA Group shall, correctly and at appropriate timings, prepare and maintain accounting records of all transactions, expenditures and asset dispositions in accordance with the group’s in-house rules and procedures.

6. Action upon Violation

KAMEDA SEIKA Group shall endeavor to find any action or threatened action prohibited under provisions 2, 3 or 4 in an early stage. If KAMEDA SEIKA Group finds any such action or threatened action, KAMEDA SEIKA Group shall strictly conduct investigation and provide punishment and fully cooperate with the relevant authorities.

7. Revision

Compliance with laws and regulations in the business activities, prohibition of unfair profits or benefits provision to any particular person(s), and implementation of fair and sincere transactions, all of which are described in the code of conduct of the group, shall be the basic principles of this policy. On the basis of these principles, KAMEDA SEIKA Group will immediately revise the policy when required.

Explanation of terms

“Laws and Regulations Related to Bribery Prevention” (examples are listed below)

Japan:
National Public Service Ethics Act, National Public Service Ethics Code, Ethics-related regulations provided by special corporations and local governments, Unfair Competition Prevention Act, Penal Code, Companies Act and other related laws and regulations
U.S:
Foreign Corrupt Practices Act
U.K.
Bribery Act 2010

Other laws and regulations to prevent bribery established by the relevant countries or areas

“Public Officials” (examples are listed below)

Those engaged in public duties of the government or local governments;
Those engaged in administrative works of government-related organizations;
Officers and employees of public enterprises;
Those engaged in public duties of international organizations;
Those entrusted with authorities by the government, local governments or international organizations;
Officers and staff members of political parties;
Candidates for public offices; or
Those similar to above

“Money or other profits”

Anything that satisfies a person’s demand or desire (not limited to economic benefits)

Established on July 2018