Anti-Bribery Policy

1. Prohibition of Giving and Accepting Bribes

1-1 Prohibition of Giving Bribes to Public Officers

The Company does not provide, promise, demand or offer, either directly or indirectly, any monetary or other benefits for the purpose of exerting influence on the performance of the public duties or decisions of any domestic or foreign public officers, persons equivalent thereto or persons intending to become the same (collectively, “Public Officers”), in order to obtain unlawful gains in bidding, discretionary contracts, etc.


1-2 Prohibition of Giving Bribes to Persons Other Than Public Officers

The Company does not provide, promise, demand or offer, either directly or indirectly, any monetary or other benefits for the purpose of exerting influence on the performance of the duties or decisions of any domestic or foreign counterparties pertaining to the Company’s business activities, in order to obtain unlawful gains in bid rigging or a cartel, etc., or to otherwise obtain or maintain other unjust business convenience.


1-3 Prohibition of Accepting Bribes

The Company does not accept any provision, promise, demand or offer of any monetary or other benefits that are provided for the purpose of exerting inappropriate influence on the Company’s business activities.

2. Anti-Bribery Efforts

2-1 Ensuring Thorough Raising of Awareness

In order to ensure the complete prohibition of bribery, the Company will ensure that all officers and employees comply with this Policy, and will implement awareness raising and an educational program.


2-2 Compliance Committee

The Compliance Committee, chaired by the Chief Compliance Officer, will meet on a regular basis to promote the enhancement of compliance, including the prevention of bribery.


2-3 Whistleblowing System

The Company has established a compliance consultation desk and endeavors to detect and prevent any misconduct such as bribery.


2-4 Internal Audits

The Company performs regular internal audits in accordance with the Basic Policy on Internal Control and endeavors to detect and prevent any misconduct such as bribery.

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September 1, 2023
SIGMAXYZ Investment Inc.