Policy on the Prevention of
Bribery and Corruption

HENNGE K.K. and its subsidiaries (collectively, "HENNGE") has 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 penalties for bribery.
  • 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 are criminal conducts,violation of the National Public Service Ethics Act or the National Public Service Ethics Code,or others equivalent thereto to public officers or persons in positions equivalent to public officers ("Public Officers"),whether in Japan or overseas.

* "Public Officers" include, but are not limited to, the following persons:

  1. Employees of domestic and foreign governments or local public entities;
  2. Officers and employees of domestic and foreign government-affiliated companies or government-affiliated entities;
  3. Officers and employees of corporations who are treated in the same way as public officers according to domestic and foreign laws and regulations (so-called "deemed public officers");
  4. Officers and employees of international organizations;
  5. Officers and employees of business operators acting under delegation of authority from domestic and foreign governments or local public entities, or international organizations;
  6. Members of the national parliament and members of local assemblies;
  7. Officials and members of political parties and political organizations;
  8. Candidates for public office; and
  9. Relatives etc. of the persons referred to in items (1) to (8) above.

* "Business entertainment, gifts, benefits, and other advantages" include, but are not limited to, the following:

  1. Cash, cash vouchers, gift cards, loans, securities, and guarantees;
  2. Invitations to sporting events, theatre performances, travel, and other such activities;
  3. Donations and sponsorship costs;
  4. Gratuities, rebates, sales promotion expenses, and discounts;
  5. Facilitation payments (payment of small amounts requested by Public Officers of a foreign country in relation to customs clearance,inspections, applications for issuing or extension of entry or residence visas,construction of water and sewerage or telephone facilities,and similar matters, which are not based on relevant laws and regulations of the country concerned); and
  6. Employment opportunities for persons concerned or their relatives.

3.Prohibition of Providing Advantages to Business Partners Other than Public Officers

HENNGE's officers and employees will not provide, offer, promise to provide, or approve business entertainment, gifts, benefits, or other advantages that are criminal conducts, violation of internal rules of the business partners, or others equivalent thereto 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.

* "Business partners" include all organizations and individuals that conduct transactions with HENNGE, such as customers, agencies, and partners, regardless of their names.

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

    1. Compliance with Internal Rules
    2. 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 prevention of bribery and corruption.

    3. Compliance Committee
    4. 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 meet at least once a month.

    5. Establishment and Operation of Internal Consultation System and Whistleblower System
    6. 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.

    7. Internal Audits
    8. 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 Section.

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.

Last revised on April 1, 2022