SAKATA INX Group
Anti-Corruption Basic Policy

SAKATA INX Group (hereinafter referred to as “We”) comply with all applicable laws and regulations and international rules in the countries and regions that we conduct business based on high ethics and social common sense.
We, hereby, establish the “SAKATA INX Group Anti-Corruption Basic Policy” (hereinafter referred to as “this Policy”) as the guiding principle to prevent all forms of corruption.

1. Purpose

The purpose of this Policy is to prevent the corruption of all officers, directors and employees of SAKATA INX Group, and to comply with all applicable anti-corruption laws and regulations and to establish and maintain fair business practices free of any acts of corruption.

2. Scope of Application

This Policy is applied to all officers, directors and employees including person equivalent thereto of SAKATA INX Group (hereinafter referred to as “Employees”).

3. Compliance

Employees will comply with this Policy and all applicable anti-corruption laws and regulations including but not limited to criminal laws, competition laws (including but not limited to Japanese Antimonopoly Act and Unfair Competition Prevention Act) , U.S. Foreign Corrupt Practices Act and U.K. Bribery Act.

4. Prohibited Activities

Employees will not conduct acts of corruption including but not limited to Offer of Bribe to public officials including person equivalent thereto and non-public officials (collectively “Public Officials and Non-Public Officials”), Acceptance of Bribe, embezzlement, breach of trust and collusion. “Offer of Bribe” means to give, offer or promise any money or other benefit to Public Officials and Non-Public Officials in order to have them act or refrain from acting in relation to the performance of duties, or in order to have Public Officials and Non-Public Officials use their position to influence other Public Officials and Non-Public Officials to act or refrain from acting in relation to the performance of duties, for the purpose of making any wrongful gain in business with regard to commercial transactions. “Acceptance of Bribe” means to receive, offer or promise any money or other benefit in relation to the performance of duties in order to make any wrongful gain in business with regard to commercial transactions.

5. Education and Training

We will thoroughly notify this Policy and operate this Policy. We will provide proper education and training in order to promote compliance and ethical values.

6. Record and Storage

We will accurately record accounting records based on facts for all transactions. We will properly keep related reports and documents in accordance with each SAKATA INX Group’s company rules. We will monitor and conduct audits on a regular basis.

7. Improvement of Anti-Corruption System

We will monitor and conduct audits on a regular basis to prevent corruption and make efforts to improve our anti-corruption system.

8. Response When Problems Should Occur

If any actual or potential acts of corruption are found, we will carefully conduct investigations, and will properly work with the relevant authorities if requested. We will take corrective action to prevent recurrence.