Z Holdings Group Basic Policy on Anti-Corruption

Article 1 (Purpose)

  • The purpose of this Basic Policy is to promote anti-corruption efforts throughout the Z Holdings Group in the spirit of fair play, and to secure the trust of stakeholders and society in general by clarifying the policies on which the Z Holdings Group and all its officers and employees (hereinafter referred to as the “Officers and Employees”) should base their anti-corruption efforts, in accordance with the Charter of Corporate Behavior and the Z Holdings Group Code of Conduct.

Article 2 (Scope of application)

  • This Basic Policy shall be applied to the Z Holdings Group and all its Officers and Employees, regardless of the country or region in which they operate.

Article 3 (Compliance with laws and regulations related to anti-corruption)

  • Officers and Employees shall comply with all anti-corruption laws and regulations applicable in each country or region, this Basic Policy and internal rules including internal regulations (hereinafter collectively referred to as the “Related Rules, Etc.”).

Article 4 (Prohibition of giving bribery)

  1. Except as permitted by Related Rules, Etc., Officers and Employees shall not directly or indirectly provide money or other benefits, or make offers or promises thereof, to public servants, etc., and private sector customers, business partners, and other business operators (hereinafter referred to as the “Business Partners, Etc.”) with corrupt intents.
  2. Officers and Employees shall not direct bribery through third parties such as agents, consultants, distributors, subcontractors, etc., nor tolerate or condone such third parties giving bribery.

Article 5 (Prohibition of accepting bribery)

  • Officers and Employees shall not directly or indirectly receive, demand or promise to receive corrupt or unjustified benefits, with respect to their duties.

Article 6 (Thorough record-keeping and storage)

  • Officers and Employees shall comply with procedures concerning financial reporting, accurately record all transactions in accounting books, and properly store relevant materials.

Article 7 (Lawful entertainment, gifts, etc.)

  1. The Z Holdings Group shall properly manage entertainment, gifts, travel expenses, donations, support and sponsorship with public servants, etc., and Business Partners, Etc. that are lawfully provided for legitimate business purposes, in accordance with the Related Rules, Etc.
  2. The Z Holdings Group shall pay special attention to the provision of entertainment or gifts to public servants, etc., political donations, and political funds, such as by establishing separate internal rules.

Article 8 (Audit)

  • The Z Holdings Group shall appropriately operate a system for conducting self-inspections and internal audits according to the degree of risk, regarding the status of compliance with this Basic Policy and the internal rules established based on this Basic Policy.

Article 9 (Structure and response)

  1. In order to ensure a structure for complying with this Basic Policy, the Z Holdings Group shall establish internal reporting desks to which the Officers and Employees can report general compliance issues, including anti-corruption.
  2. In the event that any violation or potential violation of the Related Rules, Etc. is discovered, the Z Holdings Group shall conduct a rigorous internal investigation and fully cooperate with any investigation by the relevant authorities, etc.
  3. Officers and Employees who violate the Related Rules, Etc., may be subject to personal liability and will be subject to strict disciplinary actions in accordance with the internal regulations of the company to which they belong or their employment/delegation contract.

Article 10 (Revisions/abolition and clerical works)

  1. The revisions and abolition of this Basic Policy shall be resolved and implemented by the Board of Directors of Z Holdings Corporation.
  2. The clerical works of revision and abolition of this Basic Policy shall be conducted by the division in charge of the legal affairs of Z Holdings Corporation.

Article 11 (Enforcement)

  • This Basic Policy shall be enforced from October 1, 2021.

This is an English translation of the Japanese policy. This translation is prepared and provided for the purpose of the reader’s convenience. All readers are recommended to refer to the original version in Japanese for complete information.