HENNGE
Policy on the Prevention of
Bribery and Corruption
HENNGE K.K. and its subsidiaries (collectively, “HENNGE”) have adopted the vision of “Change Society through Liberation of Technology” since it was founded. By making the benefits of our unique technologies and cutting-edge technologies readily available to corporations and providing them as new value, we have expanded our business to contribute to global development.
In recent years, regulations against bribery and corruption have been strengthened in each country around the world, including Japan. This has shaped a common recognition that responsible companies should actively strive to prevent bribery and corruption.
As a duty of HENNGE in its aim of contributing to global development, and under the principle that liberation of technology is not compatible with social development through bribery and corruption, HENNGE has endeavored to work proactively to prevent bribery and corruption.
To make clear our determination not to allow any bribery or corruption for any reason whatsoever, we have now established the HENNGE Policy on the Prevention of Bribery and Corruption. Based on this policy, HENNGE will further enhance its systems for the prevention of bribery and corruption.
1. HENNGE’s Basic Policy
- We will comply with domestic and foreign laws and regulations, etc., stipulating the prevention of bribery and corruption and penalties for such actions.
- We will not give kickbacks, rebates, or the like to influence solely employees or persons in charge of the counterparties to transactions.
- We will not engage in any markedly inappropriate business entertainment contrary to public policy, or accept offers to provide such business entertainment.
- We will prepare and retain accurate accounting records of the content of business entertainment provided or received by HENNGE and will increase transparency within the company.
2. Prohibition of Bribery of Public Officers
HENNGE’s officers and employees will not provide, offer, promise to provide, or approve any business entertainment, gifts, benefits, or other advantages that constitute criminal conduct, violations of the National Public Service Ethics Act or the National Public Service Ethics Code, or other acts equivalent thereto, as consideration for facilitating business, to public officers or persons in positions equivalent to public officers (“Public Officers”), whether in Japan or overseas.
3. Prohibition of Providing Wrongful Advantages to Business Partners Other than Public Officers
HENNGE’s officers and employees will not provide, offer, promise to provide, or approve any business entertainment, gifts, benefits, or other advantages that constitute criminal conduct, violations of the internal rules of business partners, or other acts equivalent thereto, as consideration for facilitating business, to business partners that do not fall under Public Officers, or the officers and employees, etc. of such business partners, whether in Japan or overseas.
4. Prohibition of Accepting Personal Advantages
HENNGE’s officers and employees will not request, promise to accept, or accept business entertainment, gifts, benefits, or other advantages as consideration for facilitating business without examination and approval by, or reporting to HENNGE in accordance with rules separately established by HENNGE, whether in Japan or overseas.
5. Thorough Management of Records and Ensuring Transparency within the Company
HENNGE will prepare and maintain timely and accurate accounting records with respect to all transactions and disposition of assets. It will also ensure transparency within the company concerning expenditure of costs related to this policy such as business entertainment costs, as well as benefits received by individual executives and employees. HENNGE will establish a system under which in the event of any private use by HENNGE’s officers and employees, who are in charge of its business, of any products or services provided by partners (including their officers or employees) of such business, certain reports with clear description thereof shall be secured.
6. Establishment of Systems for Preventing Bribery and Corruption
- Compliance with Internal Rules
HENNGE has stipulated internal rules for the prevention of bribery and corruption and, as well as ensuring that all officers and employees comply with those rules, it conducts internal education to deepen their understanding of the prevention of bribery and corruption. - Compliance Committee
HENNGE will thoroughly identify and examine risks, including the prevention of bribery and corruption at its Compliance Committee, which is chaired by the Director in charge of compliance (the Representative Director and Vice President) and meets at least once a month. - Establishment and Operation of Internal Consultation System and Whistleblower System
HENNGE will further enhance its internal consultation system and Whistleblower System to enable early awareness and rectification of bribery and other illegal, wrongful, and unethical conduct within the company. It has also established a system for appropriately protecting officers and employees who have consulted or made whistleblowing reports. - Internal Audits
In accordance with its Basic Policy on the Internal Control System, HENNGE checks that its daily business execution is conducted appropriately, including awareness of risks of bribery and corruption and other wrongful conduct, through audits etc. by the Internal Audit Division.
7. Measures When Violations Occur
When HENNGE detects any actions that violate or are likely to violate this policy, it will conduct investigations without delay and, in addition to cooperating in good faith with investigations of relevant authorities, will carry out disciplinary procedures as necessary.
Enacted on April 1, 2022
Revised on March 1, 2024
Revised on January 1, 2025