Based on Matsuda Sangyo Group Bribery Prevention Policy, we, Matsuda Sangyo Group*, recognize that it has an important responsibility to conduct its business with integrity and fairness in response to recent growing global concerns in relation to bribery as it expands its business operations in Japan and overseas, and hereby pledges to strive to prevent bribery in accordance with the policy below.
Matsuda Sangyo Group will comply with the Penal Code of Japan, the Unfair Competition Prevention Act, and other relevant bribery prevention laws and regulations of foreign countries (“Relevant Laws and Regulations”).
Matsuda Sangyo Group shall not engage in any of the following:
（１）Bribery of Government Officials, etc.
Officers or employees of Matsuda Sangyo Group (“Officers and Employees, etc.”), in violation of Relevant Laws and Regulations, provide, or undertake or offer to provide, monetary or other benefits directly or indirectly to government officials or those in equivalent positions (“Government Officials, etc.”) in Japan or overseas, with the intention of influencing the performance of their duties.
（２）Bribery of Non-Government Officials
Officers and Employees, etc. of Matsuda Sangyo Group, in violation of Relevant Laws and Regulations, provide, or undertake or offer to provide, monetary or other benefits directly or indirectly to other business operators (whether corporations or natural persons) or their officers and employees, with the intention of causing such other business operators or their officers and employees to engage in unlawful or improper activities for the purpose of obtaining or retaining business benefits, whether in Japan or overseas.
（３）Bribery by Government Officials, etc. and Non-Government Officials
Officers and Employees, etc. of Matsuda Sangyo Group, in violation of Relevant Laws and Regulations, accept or undertake to accept monetary or other benefits directly or indirectly from other business operators (whether corporations or natural persons) or their officers and employees, with the purpose or intent provided in (2) above, whether in Japan or overseas, or request such benefits from such other business operators or their officers and employees.
（４）Other
Conducting any of the acts provided in paragraphs (1) through (3) above through representatives, agents, consultants, etc.
Matsuda Sangyo Group will establish a system to ensure compliance, promote fair transactions, and prevent acts of bribery and corruption as provided in the Matsuda Sangyo Group Global Code of Conduct, which all Officers and Employees, etc. shall observe.
* Matsuda Sangyo Group means the companies in which Matsuda Sangyo directly or indirectly holds a majority of the outstanding shares with voting rights or the equity, and companies in which Matsuda Sangyo has substantial control.
