Prevention of corruption and corruption

artience group (hereinafter referred to as the "Our Group") aims to achieve sustainable corporate growth by complying with the laws and regulations applicable to the countries and regions in which it conducts business activities, and engaging in business activities fairly and honestly. It expresses that. Corruption, on the other hand, obstructs market competition, violates human rights, and seriously damages the integrity of a company. We do not permit anyone engaged in the business of our group (hereinafter collectively referred to as "officers, employees, etc.") to be directly or indirectly involved in corrupt practices under any circumstances. Based on this basic philosophy, we have established the "Policy on Anti-Corruption" (hereinafter referred to as the "Policy").

1. Scope of application
   This policy applies to all officers and employees working in our group. We also ask all suppliers, distributors, and other business partners that make up our group's supply chain to comply with this policy or to understand and support its spirit.
2. Definition of corruption
   In this policy, "corrupt behavior" refers to any behavior that aims to obtain illegal profits by abusing authority.
   Specifically, bribery, excessive gifts and entertainment, conflicts of interest, improper receipt of kickbacks and kickbacks, and facilitation payments to obtain improper profits. ^*, illegal or inappropriate political contributions, anti-competitive acts such as bid-rigging and collusion, abuse of a dominant position to the detriment of business partners, extortion, blackmail, embezzlement, breach of trust, fraud, obstruction of justice, insider trading, and money laundering. (money laundering), etc., but is not limited to these.
   • Facilitation payments: Illegal payments made to public servants, etc. for the purpose of speeding up and smoothing procedures related to ordinary administrative services. Under this policy, any act of making a payment to obtain illegal profits, regardless of the amount, is considered a corrupt act.
3. Compliance with anti-corruption related laws and regulations
   We understand and comply with anti-corruption laws and regulations such as the Unfair Competition Prevention Act in Japan, as well as the relevant laws and regulations of the countries and regions where our group conducts business activities. We will also understand the purpose of the National Public Service Ethics Act, etc., work to prevent situations that violate such laws, and actively cooperate with investigations by authorities in the event of an emergency.
4. Management system to prevent corruption
   The Group will thoroughly disseminate this policy to its officers and employees, and will establish a promotion system necessary for compliance with this policy and the prevention and early detection of corrupt acts. We have built an anti-corruption management system centered on Compliance Committee, which is a subordinate organization of Sustainability Committee, and our legal department, which serves as the secretariat, promotes it at a practical level.
5. Implementation of education and training
   The Group has created and maintained this policy, internal regulations related to anti-corruption, and various anti-corruption related materials for ethics and compliance awareness activities, and made them available for viewing at all times through internal distribution and the intranet. We will strive to make everyone aware of this. At the same time, we will conduct education and training on anti-corruption regularly or repeatedly to deepen understanding and establish awareness of anti-corruption.
6. Proper accounting treatment and records
   In order to fulfill our accountability for compliance with the anti-corruption laws and regulations of the countries and regions in which we conduct our business activities and this policy, the Group shall accurately record documents and accounting books related to expenditures under an appropriate internal control system. , and store it appropriately as a trail.
7. Monitoring and continuous improvement
   The Group conducts regular self-inspections and internal audits regarding anti-corruption efforts and compliance status, and confirms whether the anti-corruption system is functioning effectively. In addition, based on the results, we will verify the effectiveness of this policy, system, and procedures, and revise and improve them as necessary.
   The Group also requests its suppliers and business partners to conduct periodic self-inspections regarding the status of their anti-corruption efforts, including investigations at the time of 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 targeted by business, the situation of the countries or regions in which business activities are conducted, business scale, etc. We will implement focused measures against high-risk business activities.
9. Establishment and operation of Internal / External Hotline
   When corruption occurs in our group, or when corruption is suspected, we will establish and appropriately operate Internal / External Hotline where officers and employees can promptly consult and report.
   Our group conducts fair investigations based on reports received through the contact point, and strives to confirm the facts and resolve the issues. In doing so, we will ensure the confidentiality of information related to the report, and take maximum steps to protect the whistleblower and investigation collaborators so that they will not be subject to retaliation or disadvantageous treatment. I will try my best.
10. Actions and penalties
    If an officer or employee who has committed or is involved in a corrupt act is a person directly employed by the Group, regardless of their position or position, the Group shall comply with the regulations and work rules of the Company or each company in the Group. will be punished strictly and promptly. If the relevant officer or employee is someone other than the person directly employed by the Group, we request that strict action be taken based on the outsourcing contract concluded between the person's employer and the Group. Masu.
    Additionally, if we become aware of corrupt practices by our suppliers or business partners, and if an investigation confirms that it is true, we will take strict action, including suspending transactions.

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