The Osaki Group declares in the "Osaki Electric Group Charter of Corporate Behavior," which is the Osaki Electric Group's Guidelines for Corporate Behavior that "we engage in fair and free competitions, appropriate transactions and responsible procurement. We also maintain a sound relationship with political bodies and government agencies."
We have established the following anti-corruption policies to ensure that we comply with local laws and regulations in the jurisdictions in which we operate and are committed not to engage in corrupt conduct*, whether direct or indirect, in any event.
*The term "corrupt conduct" as used in this policy refers to all acts of abusing authority and obtaining illegal profits, including bribery, facilitation payments to obtain illegal profits, excessive entertainment and giving and receiving of gifts, embezzlement of rebates and kickbacks, unfair competition such as collusion and bid-rigging, and money laundering.
I. Scope of This Policy
- This policy applies to all business activities of Osaki Group.
- This policy applies to all persons engaged in our business activities, including all executives and employees (including contract employees) of the Osaki Group.
II. Organizational Structure against Anti-Corruption
- Osaki Group will ensure that all persons engaged in our business activities, as well as suppliers and business agents, are aware of this policy and establish the promotion system necessary to ensure compliance with anti-corruption.
- We will endeavor to ensure fair and impartial operation by establishing a whistle-blowing hotline to promptly consult and report any violation or suspected violation of anti-corruption laws and regulations, agreements, guidelines, etc., applicable to each country or region, and this policy.
- In the event of a suspected violation of this policy, the Company will promptly investigate the facts and take appropriate measures.
- In addition to this policy, we will implement the Compliance Regulations, the Compliance Manual, and the Osaki Group Helpline System Rules to prevent corrupt practices in a multifaceted manner.
III. Implementation of Education and Training, and Dissemination of Policies
Osaki Group will conduct education and training on anti-corruption on a regular basis for all those engaged in our business activities, including the prohibition of bribery and the dissemination of internal reporting systems. In addition, we will make this policy available on our intranet and other channels at all times to ensure that it is widely known within the company.
IV. Proper Accounting and Recording
In order to fulfill its accountability for compliance with laws and regulations, regulations and guidelines related to anti-corruption and this basic policy, Osaki Group will, under an appropriate internal control system, accurately record the approval documents, accounting books, etc. related to expenditures based on facts, and properly store related forms.
V. Response to Suppliers, etc.
When selecting new business partners, such as domestic and overseas suppliers, Osaki Group will explain this policy using written documents, and ask them to endorse and practice this policy.
VI. Monitoring and Continuous Improvement
Osaki Group conducts periodic internal audits of its anti-corruption efforts and compliance in accordance with the risks of all types of corruption in the countries and regions in which it conducts business activities, and evaluates whether the anti-corruption system is functioning. Based on the results, we will improve the policy and its compliance procedures as necessary.
VII. Establishment and Operation of Hotline
Osaki Group will set up an internal whistle-blowing hotline for prompt consultation and reporting of any acts or suspected violations of anti-corruption laws, agreements, guidelines, or other applicable laws and regulations in each country or region. In the event of a report, the company shall ensure confidentiality of the whistleblower and the contents of the report, and the company shall prohibit any and all disadvantageous treatment to the whistleblower so that the whistleblower will not suffer any disadvantage as a result of the report.
VIII. Dealing with Violations
In the event that any of our officers or employees violates anti-corruption laws or these Policies, Osaki Group will strictly deal with such violations in accordance with its internal rules and employment regulations. We will also promptly notify our business partners of any plans, implementation, or knowledge of the participation or involvement of our business partners' officers or employees, and suspend any subsequent transactions.
Established: February 1, 2025
Osaki Electric Co., Ltd.
President and COO
Mitsuyasu Watanabe