HENNGE Policy on the Prevention of Bribery and Corruption
HENNGE K.K. and its subsidiaries (collectively, “HENNGE Group”) 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 socioeconomic 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 Group in its aim of contributing to global socioeconomic development, and under the principle that liberation of technology is not compatible with socioeconomic development through bribery and corruption, HENNGE Group 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 established the HENNGE Policy on the Prevention of Bribery and Corruption. Based on this policy, HENNGE Group will further enhance its systems for the prevention of bribery and corruption.
1. HENNGE Group’s Basic Policy
- We will comply with domestic and foreign laws and regulations stipulating the prevention of bribery and corruption and penalties for such actions.
- We will not engage in bribery of public officers or those in equivalent positions (hereinafter referred to as “Public Officers”).
- We will not engage in any markedly inappropriate business entertainment with private business partners, or accept offers to provide such business entertainment.
- We will prepare and retain accurate accounting records of business entertainment provided or received by HENNGE and will increase transparency within the company.
- We will establish a system to prevent bribery and corruption, and will respond appropriately to any violations.
2. Prohibition of Bribery of Public Officers
HENNGE Group will not offer, promise to provide, or provide any business entertainment, gifts, benefits, or other advantages that violate domestic or international anti-bribery and anti-corruption laws and regulations, to Public Officers, whether in Japan or overseas.
3. Prohibition of Providing Wrongful Advantages to and Accepting Wrongful Advantages from Business Partners
HENNGE Group will not offer, promise to provide, provide, or accept any business entertainment, gifts, benefits, or other advantages that violate domestic or international anti-bribery and anti-corruption laws and regulations, to business partners or the officers, employees, etc. of such business partners, whether in Japan or overseas. Even when there is no violation of the law and regulations of each country relevant to such action, any excessive business entertainment or gifts, or any other actions deemed inappropriate will be addressed in the same manner.
4. Thorough Approval Procedures
HENNGE Group will not request, promise to accept, or accept business entertainment, gifts, benefits, or other advantages 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 Group 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 individually received by its officers, employees, etc.
6. Establishment of Systems for Preventing Bribery and Corruption
- Compliance with Internal Rules
HENNGE Group has stipulated internal rules for the prevention of bribery and corruption and, as well as ensuring that all its officers, employees, etc. 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 related to bribery and corruption within HENNGE Group at its Compliance Committee, which is chaired by the Director in charge of compliance (the Representative Director and Vice President). - Establishment and Operation of Consultation System and Whistleblower System
HENNGE Group will further enhance its 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 Group 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 Group 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
Revised on April 1, 2025