Snow Peak Anti-Corruption Basic Policy
In accordance with our cherished mission statement, the Snow Peak Group, consisting of Snow
Peak, Inc., its subsidiaries, and affiliates (hereinafter referred to collectively as "Snow Peak"),has established the basic policy on anti-corruption initiatives (hereinafter referred to as the"Basic Policy") for all officers and employees of Snow Peak and its group companies (hereinafterreferred to as "Officers and Employees"). The purpose of disclosing this Basic Policy is topromote the anti-corruption efforts of the entire Snow Peak and to earn the trust and confidenceof all stakeholders by clearly stating this Basic Policy.
1. Compliance with Laws and Regulations
Officers and Employees are required to comply with all applicable anti-corruption laws andregulations, ordinances and rules in each country or region in accordance with internal rules,internal regulations, manuals, or other applicable rules established by Snow Peak (hereinafterreferred to collectively as the "Internal Rules etc.").
2. Prohibition of Corruption
Officers and Employees must not engage corruption (meaning any act which acquiring wrongful
benefits in abuse of its power. This includes to provide, offer, or promise money or benefits topublic officials, business partners, or other parties with the wrongful intention of corrupting
them or accept these money or benefits; to give instructions or tacit approval to bribery throughthird parties; and to demand or promise, or accept any wrongful or unjust benefits.).
3. Thorough Record Keeping and Safekeeping
Officers and Employees must ensure that financial reporting procedures are followed, that
accurate records are kept, and that relevant materials are properly archived.
4. Lawful Entertainment, Gifts, etc.
Officers and Employees must appropriately manage entertainment, gifts, travel expenses,donations, support, or sponsorship with public officials etc. and business partners etc. that havelegitimate business purposes and are provided or received lawfully, in accordance with theInternal Rules etc.. Particular attention should be paid to entertainment and gifts to public
officials, etc., as well as political contributions and provision of political funds. Also, whenchoosing agents or consulting etc., Officers and Employees will hire reliable person andorganization based on sufficient investigation and request them to act in accordance with theBasic Policy and to comply with all applicable anti-corruption laws and regulations, ordinancesand rules. In relation to agents or consulting etc., entertainment and gifts beyond common senseshall not be received or provided.
5. Education
Snow Peak will provide appropriate training on compliance of the Basic Policy and the Internal
Rules etc. for all Officers and Employees.
6. Donation
Snow Peak will donate for a lawful charity purpose and in accordance with the policies of Snow
peak and check sufficiently that it does not fall under corruption when making a donation.
7. Facilitation Payments
Snow Peak prohibits “facilitation payment”. “Facilitation payment” means a payment to public
officials for expediting the performance or procedure related to their duties or otheradministrative services.
8. Auditing
Snow Peak must establish a system to confirm compliance of Officers and Employees with theBasic Policy and the Internal Rules etc. by appropriately conducting self-inspections and internal
audits according to the degree of risk.
9. System and Response
In order to ensure compliance with this Basic Policy, the Snow Peak has established awhistleblower hotline where Officers and Employees can report compliance issues, including
anti-corruption. In the event where Snow Peak find a violation of the Internal Rules etc., arigorous internal investigation will be conducted and cooperation with the relevant authorities
will be provided. Violating Officers and Employees will be subject to strict disciplinary action inaccordance with the rules of employment and the Internal Rules etc. to which they belong, inaddition to possible legal liability.
10. Revision, Abolition, and Management
Revision or abolition of the Basic Policy shall be made by a decision of the Board of Directors.
The General Affairs Division is in charge of operations related to the revision or abolition of theBasic Policy.
Established: December 13, 2023
Snow Peak, Inc.
Tohru Yamai
Representative Director, Chairperson, President and CEO