Policy for preventing bribery and corruption

Basic way of thinking

The purposes of this policy are to demand that all members of the Monogatari Corporation observe laws and ordinances related to the prevention of bribery in Japan and all other countries, and to thoroughly prevent acts of bribery and corruption as well as acts that encourage bribery and corruption (hereinafter referred to as “acts of bribery and corruption, etc.”).

Scope of application

This policy applies to all members of the Monogatari Corporation. Also, we request that all business partners involved in our products and services understand and observe this policy as well.

Prohibition of acts of bribery and corruption, etc.

All members inside or outside of Japan shall not directly or indirectly engage in the provision of money or other benefits*2 for the purpose of unjustly obtaining benefits or make such an offer or promise regardless of whether the other party is a public servant*1 or a private citizen. Also, all members shall not directly or indirectly conduct any act related to corruption that misuses the authority or position of themselves in business in relation to their professional duties (including collusion, embezzlement, breach of trust, obstruction of justice, and money laundering) for the purpose of obtaining gains for an individual or organization, and they shall not demand or receive unfair or unjust profits.

Facilitation payment

We prohibit the payment of a small amount of money to a public official (facilitation payment) in order to make the procedure of daily administrative services smooth and speedy, except in cases where the laws and ordinances related to the prevention of bribery in the country where we are active explicitly allow such practice.

Payment recording management

In a case where we provide money or other benefits to a third party with which we come into contact in the course of the execution of our business, all members shall appropriately retain documented evidence of the grounds for such action, accurately record the amount of money or other benefits in the account ledger without omission, and shall not process a transaction without being accounted for.

Establishment of a system aimed at preventing the acts of bribery and corruption, etc.

1. Awareness and thorough prevention of the acts of bribery and corruption, etc.

   In order to thoroughly prevent the acts of bribery and corruption, etc. mentioned above, we have established the regulations for compliance and risk management and the policy for preventing bribery and corruption as in-house regulations, and all members are to observe them. Also, we regularly conduct employee education in order to increase their understanding of these regulations.

2. Establishment of a committee for compliance and risk management

   We have established a committee for compliance and risk management as a consultative body that brings together related divisions to discuss compliance issues, and through the understanding and careful examination of evident and latent risks with a particular focus on the prevention of the acts of bribery and corruption, etc., we make efforts to develop and operate a compliance system according to the status of our business developments and organizational system in a sophisticated manner.

3. Internal audit

   We have the internal audit office audit the status of the establishment and operation of the compliance system set forth in the “Basic policy related to the internal control system,” and check whether the daily execution of our business is being conducted properly, while recognizing the risks of unjust acts such as the acts of bribery and corruption, etc. Moreover, we share information on the status and results of audits with the Representative Director and President as well as outside directors, the Audit & Supervisory Board members and others, and have a system in place for the evaluation and revision of the compliance system.

4. Establishment and operation of a whistle-blowing system

   In order to quickly discover and correct illegal, unjust, and unethical acts such as the acts of bribery and corruption, etc., we have established and manage a whistle-blowing system, and established a reporting and consultation desk inside and outside the company for all members who are aware of the facts, a system for appropriately protecting all members who make reports (anonymous reports are acceptable), and set forth HR-related punishments for violators.

5. Response to the violation of this policy

   We will strictly deal with any cases in which any of all members violates this policy, based on the internal regulations of the Monogatari Corporation to which all members belong. Also, we will strictly deal with any cases in which a third party (an advisor, a consultant, a dealer, a contractor, or the like) violates this policy.