Mitsuuroko Group promotes business activities based on its Charter of Corporate Ethics and management philosophy of “As a Lifestyle Producer, we consistently conduct our business with integrity and from the customer’s perspective.”
In accordance with laws and regulations and their intentions, we prohibit the entertaining or gift-giving to public officials, etc.
We aim to conduct measures for the prevention of bribery by establishing and spreading awareness of the Charter of Corporate Ethics, employment rules, Compliance Rules, and risk management rules, etc.
The Group enacted a basic policy related to prevention of bribery overseas and in Japan as it conducts global business.
We understand that it is the duty of each Mitsuuroko Group company, officer, and employee to comply with this basic policy. As such, we make the following declaration.
In accordance with our Basic Policy on Prevention of Bribery, we shall comply with the laws applied in each country and region and not engage in bribery of foreign officials.
By clarifying the policies that are the foundation of this basic policy, we promote efforts to prevent bribery across all of Mitsuuroko Group with a mindset of fair play, and realize further improvement of corporate value by fulfilling our social responsibility in order to gain the trust of stakeholders and the general public.

We understand that corruption and bribery are unacceptable and comply with Japanese Penal Code, the Unfair Competition Prevention Act, the National Public Service Ethics Act, and the National Public Service Ethics Code.
We also comply with the laws, regulations, and restrictions applied in each country and region where we conduct corporate activities and do not bribe foreign public officials, etc.
We shall not perform any actions that may lead to suspicion of bribery.

• Japan: Unfair Competition Prevention Act (Article 18), Penal Code (Articles 197 and 197-4)
• US: Foreign Corrupt Practices Act (FCPA)
• UK: UK Bribery Act 2010
• Other similar laws based on or related to treaties for the prevention of bribery of foreign officials in international trade

• Prohibition of bribery
  In corporate activities, the Company shall not offer, promise, or grant a bribe to anyone, whether they be a private citizen or a public official, either in or outside Japan, directly or through a third party, such as a proxy, consultant, or associate under contract.
  The Company shall not perform any action that may be suspected of bribery from society.
  Bribery refers to the granting and receipt of items of monetary value, or other improper interests, or the promise, demand, request, or approval thereof.

  (Notes) In the cases of charitable business, political contributions, and donations for sponsored activities, actions are also prohibited if they are in fact equivalent with bribery or improper granting of interests.
  Also, officers and employees are prohibited from instructing, suggesting, or supporting bribery of a third party such as an agent, advisor, consultant, or subcontractor hired in order to collect and analyze information, secure orders for Mitsuuroko Group, or otherwise request cooperation for the purpose of promoting business, or to request services for which Mitsuuroko Group has received orders.

• Prohibition of accepting bribes
  The Company shall constantly maintain a stance of loyalty and fairness and shall not request, promise, nor receive bribes from business partners either in or outside of Japan by using our business position.
  Also, the Company shall not perform any action that may be suspected of accepting bribes from society.

In order to prove that we do not engage in bribery, we review all payments to third parties within a logical degree of detail, record transactions accurately and surely in accounting books, and preserve these records internally for a set period.
In all circumstances, off-balance-sheet transactions are strictly prohibited.

The Company performs training related to compliance that includes education of this basic policy and regular case studies for officers and employees in order to comply with the prohibition of bribery.

The responsibility of preventing bribery, including the execution and review of this basic policy, lies with the Head of Legal & Secretary.
The Presidents of each Group company are also responsible for making their officers and employees comply with this basic policy.
Also, when we become aware of a violation of this basic policy or suspicion thereof, we will report it immediately to the manager in charge of legal affairs, the manager of the Internal Auditing, or the hotline in or outside the Company.
Mitsuuroko Group has established and spread awareness of a reporting and consultant hotline with an external attorney in order to quickly identify and correct compliance issues, including bribery.
Violations to this basic policy will be subject to punishment in accordance with various regulations.

We perform regular self-inspections of the status of compliance with this basic policy and cooperate with investigations of supervising departments in each country and region.
We will perform reviews as needed of this basic policy and compliance procedures.

The Internal Auditing performs appropriate audits related to compliance and operation of this basic policy, extracts risks and issues related to prevention of bribery, executes controls, and prevents risks beforehand.