Prevention of corruption and corruption

The artience Group (hereinafter referred to as the “Group”) hereby declares that it will aim for sustainable growth as a company by complying with applicable laws and regulations in the countries and regions in which it operates, and engaging in business activities with fairness and integrity. At the same time, corruption inhibits market competition, violates human rights, and significantly damages the integrity of the company. The Group does not permit any direct or indirect involvement in acts of corruption by its officers, corporate advisors, employees, contract employees, part-time employees, temporary dispatch workers or other persons engaged in the Group’s business operations (hereinafter referred to collectively as “officers and employees”) under any circumstances. Based on this basic philosophy, we have established this Policy on Anti-Corruption (hereinafter referred to as this “Policy.”)

1. Scope of application
   This Policy applies to all Group officers and employees. The Group also asks all suppliers, distributors, and other business partners who form the Group’s supply chain to comply with this Policy, or understand and support its spirit.
2. Definition of acts of corruption
   For the purposes of this policy, “act of corruption” refers to any act that aims to obtain an unfair advantage by abusing authority.
   Specifically, acts of corruption include, but are not limited to, bribery, excessive gifts or entertainment, conflicts of interest, wrongful receipt of rebates or kickbacks, facilitation payments* to obtain unfair profits, illegal or inappropriate political contributions, anti-competitive acts such as bid-rigging or collusion, abuse of a dominant position that disadvantages business partners, extortion, blackmail, embezzlement, breach of trust, fraud, obstruction of justice, insider trading, and money laundering, etc.^*​
   • Facilitation payment: An unlawful payment to public officials, etc., for the purpose of expediting and / or facilitating procedures relating to ordinary administrative (local government) services. Under this policy, the act of making payments to obtain unfair profits is considered an act of corruption, regardless of the amount of money paid.
3. Compliance with anti-corruption laws and regulations
   The Group understands and complies with anti-corruption laws and regulations, such as the Unfair Competition Prevention Act in Japan, as well as relevant laws and regulations in the countries and regions in which the Group operates. Moreover, with an understanding of the aims of the National Public Service Ethics Act and other laws and regulations, we strive to prevent any violation of the said laws and regulations and proactively cooperate with investigation authorities in an emergency.
4. Anti-corruption management system
   The Group will ensure that all officers and employees are fully aware of this Policy, and establish a promotion system necessary for compliance with this Policy and prevention and early detection of acts of corruption. We have established an anti-corruption management system centered on the Compliance Subcommittee (a subordinate organization of the Sustainability Committee) and the Company’s legal division, which serves as an administrative office for the management system, and implements it at a practical level.
5. Implementation of education and training
   The Group will create and maintain this Policy, internal rules relating to anti-corruption, and various anti-corruption materials in ethics and compliance awareness activities, and make them available at all times through internal handouts and the intranet, etc., to distribute anti-corruption information throughout the Group. At the same time, we will provide education and training on anti-corruption on a periodic or repetitive basis, to deepen understanding and establish awareness of anti-corruption measures.
6. Appropriate accounting and recording
   In order to ensure accountability with regard to compliance with this Policy and anti-corruption laws and regulations in the countries and regions in which it operates, the Group will keep accurate records of documents and accounting books relating to expenditures using an appropriate internal control system, and store them appropriately as evidence.
7. Monitoring and continuous improvement
   The Group will conduct periodic self-inspections and internal audits of its anti-corruption initiatives and state of compliance to check that the anti-corruption system is functioning effectively. Based on the results of these self-inspections and internal audits, we will validate the effectiveness of this Policy, the anti-corruption system and procedures, and revise and improve them as necessary.
   The Group also asks suppliers and business partners to conduct periodic self-inspections of the state of their anti-corruption initiatives, including surveys at the time of signing new contracts, and requests investigations and improvement measures depending on the situation.
8. Risk-based approach
   In identifying corruption risks and determining risk levels, the Group conducts risk assessments based on business processes, products and services covered by its business, actual conditions in the countries or regions in which it operates, the scale of its business operations, and various other factors, and implements priority measures for business activities with a high risk of corruption.
9. Establishment and operation of an internal whistleblowing system
   The Group will establish and appropriately operate an internal and external whistleblowing system whereby officers and employees can promptly consult and report in the event of an occurrence or suspicion of an act of corruption within the Group.
   The Group will conduct fair investigations based on reports made to the whistleblowing system, to confirm the facts and resolve the issue. When doing so, we will do our utmost to ensure the confidentiality of information relating to the report and protect the whistleblower and those who cooperate with the investigation so that they will not suffer retaliation or unfavorable treatment.
10. Responses and penalties
    In the event that an officer or employee who has committed or been involved in an act of corruption is directly employed by the Group, the Group will punish them strictly and promptly in accordance with the rules and employment regulations of the Company or each Group company, regardless of their post or position. In the event that the officer or employee concerned is not directly employed by the Group, the Company will request that the employer deals with the officer or employee strictly, based on an outsourcing agreement concluded between the employer and the Group.
    In addition, we also recognize acts of corruption by suppliers and business partners, and if they are confirmed as facts by investigation, we will take strict measures, including suspension of transactions.

Established on January 1, 2024 (Resolved at Board of Directors on December 8, 2023)