Anti-bribery and Corruption Policy
We, all the officers and employees of the Pigeon Group, run our business[es] with integrity. All of us
must work together to ensure our business[es] remain[s] untainted by bribery. This policy is integral tothat effort and all the officers and employees of Pigeon Group are all bound by it.
1 What are bribery and corruption?
1.1 Corruption is the misuse of office or power for private gain.
1.2 Bribery is a form of corruption. It includes offering, promising, giving, accepting or seeking a bribe.
1.3 A bribe is a financial or other advantage, promised, requested, or given to induce a public officer
or other person to perform a relevant function or activity improperly, or to reward them for doing so.
1.4 In practical terms, a financial or other advantage is likely to include cash or cash equivalent, gifts,meals, entertainment, services, loans, preferential treatment, discounts or anything else of value torecipients.
1.5 Giving or receiving benefits after the relevant event will still be considered as bribery, as will bribesthat are given or received unknowingly.
1.6 It is not necessary for the individual or organization to actually receive any benefit as a result ofthe bribe.
1.7 All forms of bribery and corruption are strictly prohibited. If you are unsure about whether
a particular act constitutes bribery, raise it with Legal Department of your company (where youbelong to).
1.8 This means that you, all the officers and employees of the Pigeon Group, must not:1.8.1 Give or offer any payment, gift, hospitality or other benefits to public officers (including officers
or employees of private companies in countries, regions that regulate bribery of officers, oremployees of private companies) in the expectation that a business advantage will be received, orto reward any business received
1.8.2 accept any offer from a third party that intends to provide business benefits to the Group, or you
think that we will provide our business advantage for them or anyone else
1.8.3 give or offer any payment or other benefits to a government official in any country to facilitate or
speed up a routine or necessary procedure
1.9 No officers and employees of Pigeon Group must threaten or retaliate against another person who
has refused to offer or accept a bribe or who has raised concerns about possible bribery orcorruption.
2 Who can be involved in bribery and corruption?
2.1 Any of the followings associated with Pigeon Group or its group companies could be involved inbribery or corruption. No officers or employees of Pigeon Group shall engage in bribery or corruption
through any of the followings
2.1.1 Employees, directors, or anyone they authorize to do things on our behalf
2.1.2 representatives who support our group’s business and other third parties who act on our behalf
2.1.3 suppliers, subcontractors, and competitors2.2 Bribery can occur in both the public and private sectors. A person receiving the bribe is usually ina position of decision making or the progress of business, sometimes a government or other publicofficial.
3 The legal position on bribery
3.1 Bribery and corruption are criminal offences in most countries where we, Pigeon Group or its
group companies, do business.
3.2 A commercial organization can also commit an offence if a person associated with it bribes anotherand does so with the intention of obtaining or retaining business or a business advantage forthe organization.
3.3 It does not matter whether the bribery or corruption occurs in the country where the groupcompanies were established or abroad. An act of bribery or corruption committed abroad may wellresult in a prosecution. Nor does it matter whether the act is done directly or indirectly.
4 Our position on bribery
We, Pigeon Group, conduct our business[es] to the highest legal and ethical standards. We will not
be party to corruption or bribery in any form. Such acts would damage our reputation and expose us,Pigeon Group, its group companies, and our staff (officers and employees), to the risk of fines andimprisonment. We take a zero-tolerance approach to bribery and corruption by our employees and ourthird-party representatives.
5 What are indicators of corruption and bribery?
5.1 Common indicators of bribery and corruption include those listed below:
5.1.1 payments are for abnormal amounts or purposes (e.g. commission), or made in an unusual
way, e.g. what would normally be a single payment is made in stages, through a bank account neverpreviously used, or in a currency or via a country which has no connection with the transaction
5.1.2 approval for contract terms or commercial matters, or sign-off procedure of a decision maker isomitted, or when commercial processes are prevented from being monitored
5.1.3 individuals are secretive about certain matters or relationships and/or insist on dealing with them
personally; they may make trips at short notice without explanation, or have a more lavish lifestylethan expected
5.1.4 decisions are taken for which there is no clear rationale
5.1.5 records are incomplete or missing
6 Risk assessment
6.1 We, Pigeon Group, aim to ensure our anti-bribery and corruption procedures are proportionate tothe risks we face.
6.2 We, Pigeon Group, perform a risk assessment of our organization (Pigeon group and its groupcompanies) being exposed to bribery and corruption. This Anti-bribery and corruption policy havebeen developed in response to the results of that risk assessment. Where necessary, we will review
our risk assessment and make appropriate changes to this policy.
6.3 Exceptional circumstances
6.3.1 In some circumstances a provision of benefits to public officers is justifiable.
6.3.2 If one of our staff (officers or employees) is faced with a threat to their personal safety or that ofanother person if a benefit provision is not made, they should pay it. In such cases, Legal
Department or Legal Officer must be contacted as soon as possible, and the payment and thecircumstances in which it was made must be fully documented and reported. Legal Department,Legal Officer, or Risk Management Committee will consider carefully whether to involve the police.

7 Records
It is essential that we keep full and accurate records of all our financial dealings, i.e. transparency intransactions. False or misleading records could cause significant damage to our company. be very
damaging to us.
8 Who is responsible for this policy?
The CEO of Pigeon Corporation has overall responsibility for implementing measures based on theseguidelines, and all officers and employees of Pigeon Group are obligated to comply with the relevant
provisions of this policy. They are responsible for ensuring this policy is adhered to by all staff.
9 Your responsibilities
9.1 All the officers and employees of Pigeon Group are responsible for:9.1.1 reading and being aware of the contents of this policy
9.1.2 complying with this policy
9.1.3 reporting cases where you know, or have a reasonable suspicion, that bribery or corruption has
occurred or is likely to occur
9.2 We will not penalize anyone who loses business opportunities of Pigeon Group through not paying
a bribe.
10 What should you do if you think something is wrong?
10.1 Each of employees has a responsibility to speak out if we discover anything corrupt or otherwise
improper occurring in relation to our business (see 9.1.3). If you discover or suspect bribery orcorruption with respect to any of the persons specified in 2.1.1 through 2.1.3, report it to yourdepartment head, or the Speak Up Desk. Reporting to Speak Up Desk can be done anonymously.
Non-compliance cases, including some cases handled by Speak Up Desk, will be handled by RiskManagement Committee.
11 Training
Pigeon Group conducts appropriate training on these guidelines and related policies for its staff(officers and employees). New joiners are obligated to take this training as a part of the induction
process. Further training will be provided at least every three years or whenever there is a substantialchange in the law or our group’s policy and procedure.
12 Monitoring
Our Audit Department conducts regular internal audits to make sure that these guidelines are beingadhered. Our Audit Department reports regularly to the CEO of our company on the status ofcompliance with these guidelines. Pigeon Corporation also regularly audits each Group company
always verify that this guideline is being observed. In this case, the officers and employees of theGroup must cooperate with the audit.
13 Consequences of failing to comply
13.1 All officers and employees of our group take these guidelines seriously and comply with t them.
13.2 Failure to comply puts both our staff (officers and employees) and business of our group and its
companies at risk.
13.3 You may commit a criminal offence if you fail to comply with this policy.
13.4 Because of the importance of this policy, failure to comply with any requirement may lead to
disciplinary action under our (including our group companies) procedures, and this action may resultin dismissal for gross misconduct.