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Basic Policy for Prohibition of Bribery

ADEKA Group's Basic Policy of Prohibiting Bribery

1. Background

In recent years, an increasing number of governments in the world have been reinforcing regulations against bribery and corruption and applying them strictly to expose bribery. ADEKA Group has upheld "legal compliance and fair and transparent business activities in accordance with social ethics" in “Code of Conduct of ADEKA Group”. The Group's compliance action guidelines for prevention of illegal conducts have specified "prohibition of offering bribes to public servants, political parties, governmental agency, etc." Considering recent developments in ADEKA Group's ongoing globalization in its business, tighter regulations and strict enforcement to expose bribery, ADEKA needs to reinforce tighter group-wide measures to cope with risk of bribery.

2. Definitions

3. Declarations and Matters to be Observed

ADEKA Group reiterates our declaration to prohibit bribery by complying with the Foreign Corrupt Practices Act (USA), the Bribery Act 2010 (UK), regulations of commercial bribes (PRC), the Unfair Competition Prevention Act (Japan), and other regulations concerning prohibition of bribery applicable in countries and regions where ADEKA Group engages in business, and to keep precise records of transactions that we engage in as well.

Furthermore, in order to eliminate bribery related to ADEKA Group's business and ensure clean business performance, ADEKA Group urges persons (agents) engaging in business or part of business on behalf of the Group and trading partners to comply with regulations of prohibiting bribery.

ADEKA Group urges all of its officers, employees, agents and trading partners to observe the followings:

1. Prohibiting bribery
Prohibiting its officers, employees, agents and trading partners from giving, offering a bribe to any person, and promising thereof, and also taking a bribe from any person regardless of whether bribing is direct or indirect.
2. Proper procedure for approval and post procedure for confirmation
Taking a proper prior approval procedure concerning payment to public servants and conducting a proper post verification procedure (review procedure).
3. Understanding of and compliance with regulations on bribes and the ADEKA Group's policy
Duly understanding and complying with regulations on prohibiting bribery and ADEKA Group's policy through training, and declaring such compliance.
4. Introducing due diligence and the provisions of prohibiting bribery into contracts with agents and/or trading partners
Engaging in business only with lawful and trustworthy agents and trading partners, taking a proper procedure for due diligence with them before engaging in business, and trying to include provisions of prohibiting bribery when concluding a contract with them.
5. Conducting periodical risk assessments
Conducting periodical assessments of the Group companies' risk of bribery.
6. Keeping records and maintaining financial control
Keeping records and maintaining financial control so that ADEKA Group can show that it complies with regulations of prohibiting bribery and ADEKA Group's policy.
7. Reviews and improvements on a periodical basis
Making periodical reviews of the policy and the control on preventing bribery,
and conducting revisions and improvements thereof, as necessary.
8. Reporting without delay
Reporting possible misconducts (bribery and corruption) to ADEKA Group’s Chief Compliance Officer without delay to enable ADEKA Group to cope with the problem timely and properly, if any of ADEKA Group's officers, employees, agents and trading partners are suspected of violating regulations of prohibiting bribery or this policy.

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