BellSystem24

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About BELLSYSTEM24

BASIC POLICY FOR PREVENTION OF BRIBERY AND CORRUPTION*

We clearly state we will engage in fair, transparent, freely competitive and appropriate transactions and relationships with politicians and authorities in the BellSystem24 Group Code of Conduct. We have also declared we will implement such transactions and relationships. Japan and other countries around the world have been tightening anti-bribery and anti-corruption regulations (Unfair Competition Prevention Act in Japan, Foreign Corrupt Practices Act in the U.S. and Bribery Act in the U.K., etc.) in recent years. Against this backdrop, we have enacted this policy to comply with anti-bribery laws/ordinances in the countries and regions where we engage in business and to promote transparent and honest behavior. We are striving to prevent bribery and corruption through the code of behavior we have stipulated in this policy, throughout the company-wide supply chain, including all suppliers.

Code of Behavior

(Scope of Application)
This policy applies to all the officers and employees including contractors and temporary employees in our group. (Our group refers to BellSystem24 Holdings, Inc. and subsidiaries.)

1. Compliance with Laws/Ordinances

  • Our group shall comply with anti-bribery and anti-corruption laws/ordinances in all the countries and regions which apply to us.

2. Prohibition of Bribery

  • Our group and our officers and employees shall never provide unfair advantages either directly or indirectly to public officers.

3. Dealings with Third Parties

  • Our group and our officers and employees shall not provide unfair advantages to public officers through consultants or other third parties.

4. Accurate Records and Monitoring

  • Our group shall accurately record account books based on the facts and appropriately manage the related forms to comply with anti-bribery and anti-corruption laws/ordinances in all countries and regions. Our group shall conduct an audit as appropriate on all operations with this policy. We shall audit this policy periodically.

5. Response to Problems

  • If any of our group's officers or employees violates this policy, we shall appropriately and promptly punish them in accordance with our internal rules.
  • * Bribery: This refers to giving public officials or those equivalent to that money, gifts, entertainment, benefits or other economic advantages (including facilitation payments) in relation to their duties which are to obtain an unfair advantage in business or which are beyond the bounds of social protocol. This also applies to cases when it appears payments to agents, advisors or consultants are used to illegally influence public officials or those equivalent to that. It refers to giving officers and employees of business partners economic advantages beyond socially-accepted norms. It also refers to accepting economic advantages beyond socially-accepted norms from officers and employees of business partners. The aforementioned "money, gifts, entertainment or other economic advantages" also include cash and coupons, loans and guarantees, invitations, donations and sponsorship fees, rewards and rebates, and unfair job placement for relatives.
  • * Corruption: This refers to the abuse of delegated official power for personal gain. Examples include embezzlement, insider trading, bid-rigging and money laundering.
  • * We prohibit commercial bribes which constitute improper provision of advantages to our business partners in the private sector.
  • * We prohibit our officers and employees from receiving improper advantages from our business partners in the private sector.
  • * We prohibit the provision of entertainment or the presentation of gifts to public officials in Japan or overseas.
  • * We conduct due diligence from the perspective of preventing corruption when considering investment projects.
  • * We make decisions according to strict internal review rules so that contributions and sponsorships do not become acts of corruption in relation to political contributions, charities and sponsorship activities.
  • * We distribute code of conduct pamphlets and provide training on compliance to all our employees including our contract employees.
  • * In all of the above policies, the Board of Directors and the Board of Corporate Auditors provide thorough oversight across the company.
Established October 1, 2021
Revised April 1, 2022
Hiroshi Kajiwara, Representative Director, President and CEO
BELLSYSTEM24 Holdings, Inc.