Asahi Intecc Group Anti-Bribery Policy

1. Purpose

ASAHI INTECC CO., LTD. and its subsidiaries (hereinafter referred to as the "Group") have as its corporate philosophy to realize the "Dreams" of all customers and contribute to society at large by continuously providing the world with "Only One" technology and "Number One" products based on safety and reliability in the medical and industrial equipment fields. In order to achieve these goals, the Group has established this policy based on the recognition that it is essential to conduct fair, transparent, and free transactions and competition, and to earn the trust of society, including those who are involved in its business activities.

2. Scope of Application

This policy applies to all directors, officers and employees of the Group. The Group also requires third parties involved in the Group's business activities, such as business partners, to comply with this policy.

3. Compliance with Laws and Regulations

The Group complies with international laws and regulations, such as the OECD Anti-Bribery Convention, the Foreign Corrupt Practices Act of the United States, and the Bribery Act 2010 of the United Kingdom, as well as domestic laws and regulations, such as the Unfair Competition Prevention Act of Japan, in order to conduct its business in a transparent and bribery-free manner.

4. Prohibition of Bribe-Giving

1) Prohibition of bribe-giving to public officials, etc.

All directors, officers and employees of the Group will not, directly or indirectly, provide any form of monetary or any other tangible or intangible benefit (including any offer or promise of the same) to any government, local government, government-related organization, public international organization, public corporation, public hospital, government-designated inspection agency, or government-designated testing agency of any country (hereinafter referred to as "Public Officials, etc.") in order to obtain or retain any improper advantage.

2) Prohibition of bribe-giving to person other than Public Officials, etc.

We will not offer, directly or indirectly, any form of monetary or any other tangible or intangible benefit (including any offer or promise of the same), to any person other than Public Officials, etc., for any of the following purposes:

1. To obtain or retain business or to obtain or retain an advantageous position in the conduct of business; or
2. To induce the commission of any illegal or dishonest act.

3) Prohibition of bribe-taking

The Group will not receive any tangible or intangible benefit, monetary or otherwise, from any business partner or other third party. However, the Group may receive entertainment, gifts, etc. within the scope of socially accepted norms, provided that such entertainment, gifts, etc. are approved and reported in accordance with the rules separately established by the Group, and that transparency is ensured.

5. Accurate Recording and Control

The Group will record its accounting books and financial statements accurately based on facts and manages them properly.

6. Responding to Violations

The Group will promptly and thoroughly investigate any suspected bribe-giving or bribe-taking by any of its directors, officers, employees, or third parties associated with its business activities. If bribe-giving or bribe-taking is confirmed, the Group will cooperate with investigations by the authorities and take strict action, including disciplinary action and dismissal.

7. Continuous Improvement

This policy and the anti-bribery measures based on it will be continuously reviewed and improved as necessary in accordance with the business environment in which the Group operates and the trends in domestic and foreign laws and regulations.

ASAHI INTECC CO., LTD.
President & CEO
Kenji Miyata


Established on May 14, 2024
Revised on September 1, 2024