CCBJH Group Anti-Bribery Policy

１．Policy Summary
The nature of the business of Coca-Cola Bottlers Japan Holdings Group (hereafter “OurGroup”) requires that we interact with various government officials, etc. (as definedlater). The laws and ordinances, Our Group Code of Business Conduct & Ethics, and thisPolicy establish certain limits on the interactions with government officials, etc.,
particularly where we might be providing something of value to a government official, etc.
This policy is intended to provide our employees with a level of awareness about laws andregulations associated with anti-bribery in order to avoid inadvertent violations as well as
to recognize potential issues in time for them to be addressed appropriately. A violationof laws and regulations associated with anti-bribery can lead to severe administrative andcriminal penalties; therefore, it is vital that we not only understand and appreciate theimportance of this Policy, but comply with it in our daily work.
Under this policy, the offering or acceptance of corrupt payment and other advantages
between private (non-government) persons and entities shall constitute commercial
bribery and be prohibited.

２．Policy Applies To/ Eligibility
This Policy applies to all employees of Our Group including officers.

３．Policy Background
Our Group must carry on its business with integrity based on the Code of BusinessConduct & Ethics. This means avoiding corruption of all kinds, including bribery of
government officials, etc.
Our Group has employees from many countries and conducts business activities globallysuch as procurement from overseas; thus, it is important to comply with laws andregulations associated with anti-bribery in the countries and areas where our business
partners locate in addition to those in Japan.
In addition, Our Group has incorporated a prohibition against bribery into our Code ofBusiness Conduct & Ethics, and this Policy provides explanation on the prevention of
improper payments and permissible payments under all laws and regulations associated toanti-bribery that we must comply with (the criminal law, Unfair Competition Prevention
Act, National Public Service Ethics Act , the Companies Act, U.S. Foreign Corrupt
Practices Act (hereinafter referred to as “FCPA”), and the U.K. Bribery Act (hereinafter
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1referred to as “UKBA”) and, China Unfair Competition Prevention Act (hereinafterreferred to as “CUCPA”), etc. These laws and ordinances will be collectively referred toas “Applicable Corruption Laws” in this Policy.
When Applicable Corruption Laws are violated, in many cases, the person violated thelaws will be sentenced or fined regardless of his/her nationality. Moreover, it is possiblethat Our Group is fined also, which creates massive damage to the trust and reputation of
Our Group as well as to the Coca-Cola business

４．Definition
For the purposes of this Policy, the term “Government Official” is broadly defined toinclude:(1) Any officer or employee of any government entity, department, or agency(2) Any employee of a national or public-owned business, school, hospital, or other entity(3) Any political party, officer, or employee thereof(4) Any politician or candidate for political office(5) Any employee or official of a public international organization, department, or agency
thereof (e.g., the United Nations, Olympic Organizing Committee, FIFA Committee,
and World Bank
(6) Any person acting in an official capacity on behalf of a government entity(7) Deemed public servants (officers or employee of those entities (public corporation,
institution, fund, incorporated administrative agency, and promotion association)
deemed to be public servants by the laws and regulations ＊）＊ If any concern arises on how to correspond with officers and employees of anorganization, it is required to refer to the purpose of its foundation and regulations
concerning duties and penalties.
(8) The term “Government Official” in this Policy also includes “Foreign Public Official”
which is defined by the Unfair Competition Prevention Act as follows
i. Any person who engages in public services for a national or local foreign
government
ii. Any person who engages in services for an agency affiliated with a foreign national
governmentiii. Any person who engages in services for a foreign public enterprise
iv. Any person who engages in public services for an International Organizationv. Any person who exercises a public function on behalf of a foreign national
government, etc. as delegated

５．Prohibited Payment on Applicable Corruption Laws
Applicable Corruption Laws prohibit companies and their employees and representatives
from giving, promising, offering, or authorizing payment of anything of value to any
government official, etc. in order to obtain or keep business or to secure some otherimproper advantage. In essence, these laws prohibit the giving of anything of value toinfluence actions of a government official, etc. Prohibited payments include, but are notlimited to, those aim to:(1) Induce the recipient to award a contract to Our Group;
CCBJI Group Anti-Bribery Policy2(2) Obtain advantageous tax or customs treatment that would not otherwise be available
to Our Group; or(3) Circumvent or cause non-enforcement of laws or regulations applicable to thecompany.

６．Prohibition on Bribery
Applicable Corruption Laws prohibit companies and their employees and representatives
from giving, promising, offering, or authorizing payment of anything of value to any
government official, etc. in order to obtain or keep business or to secure some otherimproper advantage. In essence, these laws prohibit the giving of anything of value toinfluence actions of a government official, etc. Prohibited payments include, but are notlimited to, those aim to:(1) The benefit is for someone other than the party making the payment.
(2) The business sought is not with the government organizations.
(3) The payment does not in fact influence the government official’s conduct.
(4) The government official initially suggested the payment.

７．Prohibition on Commercial Bribery
The UKBA and CUCPA specifically prohibit the offering or acceptance of corrupt
payments and other advantages between private (non-government) persons and entities.
Such conduct constitutes commercial bribery, such conduct is prohibited by Our Group
Code of Business Conduct & Ethics.

８．Facilitating Payments
Facilitating (or expediting) payments (i.e. gratuity) (hereinafter referred to as “Facilitating
payment”) also are prohibited under this Policy. Facilitating Payments for Facilitation aresmall payments paid to lower-grade public officers in order to expedite or facilitate nondiscretionary actions or services or typical government procedures.
As the examples from overseas, obtaining an ordinary license or business permit,
processing government papers such as visas, providing police protection, providing
telephone, power, or water service, or loading or unloading of cargo falls under thiscategory.
Especially when you encounter a situation that you believe may require a facilitating
payment to government official, etc. in overseas, contact Our Group’s Legal ComplianceDepartment for consultation.

９．Prior Approval from Legal Compliance Department(1) Duty of prior approval
Our Group Code of Business Conduct and Ethics and this Policy require employees
to obtain approval from Legal Compliance Department before providing anything ofvalue to a government official, etc.
(2) Exception
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There is an exception to this general rule:
Payments are permissible without prior approval when an employee’s safety is at
issue, as for example when a payment must be made immediately to ensure safe
passage out of a particularly dangerous geography. Employees should make whatever
payment is necessary to protect their personal safety, and then, as reasonable, report
the nature of the incident and related payment to Legal Compliance Department.
(3) Prior Consultation
Anti-bribery matters are not always clear and must often be addressed on a case-bycase basis.
In all situations where there is a question, employees should consult Legal
Compliance Department.

10．Limited Exceptions(1) Gifts, Meals, and Entertainment
It is not always easy to identify whether providing gifts, meals, and entertainment (orother hospitality) would be considered a corrupt act under Applicable Corruption Laws.
It may be permissible under such laws to provide modest gifts or a meal or otherentertainment to a government official as a social amenity. Generally, gifts, meals, andentertainment are permissible, provided that:i. There is no expectation that the gift, meal, or entertainment is given in exchange
for any return favor or business advantage from the government organizations;ii. The gift, meal, or entertainment is infrequent, reasonable, and proportionate inamount under the circumstances; andiii. An approval is obtained from Legal Compliance Department beforehand.
When deciding whether a gift is appropriate, employees must take into account any pastor future administrative matters that are within the recipient’s realm of influence. The
timing and context surrounding such gifting must be weighed in order to assess whether
any particular gifting could objectively be perceived to be a bribe.
Before providing any gift, meal, or entertainment to a government official, always seek
approval from Legal Compliance Department.
(2) Donations
It is sometimes permissible under Applicable Corruption Laws to make donations
directly to government organizations (rather than to an individual government official)
as part of a charitable effort or to promote goodwill through such actions as providing
products to a government organization-sponsored celebration. Donations made togovernment organizations are permissible, provided that:i. There is no expectation that the donation is given in exchange for any return favor
or business advantage from the government organization;
ii. The donation is not made directly to an individual government official, and there isno indication that the donation will be redirected to an individual official’s personaluse; andiii. The donation is infrequent and reasonable in amount under the circumstances.
Donations to private charities should not be made in the name of a government official,
as a donation to an official’s favorite charity could be viewed as a bribe.
In addition, Our Group specifies those with approval authority over donations in the

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4Regulations of Authority and Responsibility stipulated separately from this Policy. All
donations made on behalf of Our Group must follow the process specified in theRegulations of Authority and Responsibility. For more information, please refer to theRegulations of Authority and Responsibility.
(3) Political Contribution
Our Group specifies those with approval authority over political contributions in theRegulations of Authority and Responsibility stipulated separately from this Policy. All
political contributions made on behalf of Our Group must follow the process specified in
the Regulations of Authority and Responsibility. For more information, please refer tothe Regulations of Authority and Responsibility.
(4) Hiring or Engaging Government Official
Our Group prohibits hiring of government officials as general rule.

11．Third Parties(1) Prohibition of Unlawful Payment via Third Parties
Applicable Corruption Laws with which we must comply prohibit corrupt payments madedirectly by employees of Our Group or indirectly through an agent or otherintermediary such as a consultant acting for or on behalf of Our Group (hereinafterreferred to as “Third Party”).
It is unlawful to make a payment of anything of value to any person, knowing that all or
any portion of the payment will be offered, given, or promised to a government official
or any other person for a corrupt purpose. The term “knowing” includes conscious
disregard, deliberate ignorance, and willful blindness. In other words, Our Group andindividual employees may violate the FCPA if we have “reason to know” or “shouldhave known” that an agent will bribe a government official, etc.
Our Group can be held criminally liable for bribes paid on its behalf by a third party insome country or area even if the company had no knowledge of the bribe.
(2) Careful Selection of Third Parties
Accordingly, the most important stem Our Group can take to protect itself from liability
for improper payments made by Third Parties is to choose carefully its business
partners, including agents and consultants.
(3) Cases that may pose risks
Moreover, these “red flags” warrant further investigation when selecting or working
with a Third Party. The following are examples of red flags:i. The transaction involves a country known for corrupt payments.
ii. The third party has a close family, personal or professional relationship to agovernment official, etc. or relative of an official, etc.
iii. The third party objects to anti-corruption representations in agreements of Our
Group.
iv. The third party requests unusual contract terms or payment arrangements (e.g.,
payment in cash, payment in foreign currency, or payment in a third country).
v. Third party is suggested by a government official, etc (particularly one withdiscretionary authority over the business at issue).
vi. The third party’s commission or fee exceeds fair and reasonable compensation for
the work to be performed.

CCBJI Group Anti-Bribery Policy5In all cases, whether or not any of these red flags are present, consult and seek
approval from Legal Compliance Department before entering into any arrangement witha third party who will have a contact with a government official, etc. on behalf of Our
Group.
(4) Due Diligence
No relationship should be developed with a third party who will have substantive
interaction with government officials, etc. on behalf of Our Group without an inquiry
into the third party's background, qualification and reputation.
When selecting a third party who will have substantive interaction with government
officials, etc. on Our Group’s behalf, necessary information to thoroughly assess the
background andreputation of the third party shall be obtained and confirm that:i. The third party is not a government official or a company in which a government
official has an interest, andii. The third party will become familiar with Our Group Code of Business Conduct &Ethics as well as Anti-Bribery Policy and certify that it will not engage in any
improper practices that could expose Our Group to liability or are otherwiseinconsistent with Our Group's business practices.
(5) Conclusion of Contract
All third party relationships that may involve contact with government officials, etc.
must be identified in written contract including articles concerning compliance with all
Applicable corruption Laws. When entering into a relation with a third party withinteraction with government officials, etc., a written contract must be concluded
including articles concerning compliance with Applicable corruption Laws. Whencreating a contract, please consult with Legal HQ.
Once an agent or consultant has been retained by Our Group, the individual's activities
and expenses must be monitored to ensure compliance with the Applicable Corruption
Laws and Company Policy.

12. Recordkeeping
To keep record accurately and properly, all employees of Our Group must:(1) Follow Our Group Code of Business Conduct & Ethics, Group procedures, andGenerally Accepted Accounting Principles;(2) Accurately record all transactions, even when the transaction might violate Applicable
Corruption Laws;(3) Never agree to request for false invoices or for payment of expenses that are unusual,excessive, inadequately described, or otherwise raise questions under regulations, laws,
and rules; and(4) Never make any payments to anonymous (i.e., “numbered”) accounts that are in thename of neither the payee nor an entity known to be controlled by the payee.

13．Auditing
Audit Section will conduct periodic audit of relevant operating units of Our Group to ensure
continued compliance to all Applicable Corruption Laws and this Policy.

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14．Ethics & Compliance Reporting Hotline
Any observation of conducts that violate this Policy, please report it to Legal ComplianceDepartment or call or send an e-mail to Ethics & Compliance Reporting Hotline. Suspectedviolations will be reviewed and investigated as appropriate and may lead to disciplinary
action.
Any retaliation for good faith reports will be violation of the Code of Business Conduct &Ethics.
Our Group prohibits any employees from taking measures that cause negative influence on
the employment of the employee based on the fact that he/she made a good faith reports for
his/her concern or cooperated with the investigation.

15．Supplementary Provisions
The policy is enacted and enforced effective April 1, 2017.
The policy is revised and enforced effective January 1, 2018.

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