Preventive Guidelines for Bribery

The subjects of these Guidelines are those persons who engage in the business
operations of the Company, such as the officers and employees, loaned employees,
contract employees, dispatched employees, etc., of the Company, its subsidiary companies
and affiliated companies.

1. Behavioral criteria (Matters to be observed as an individual)
1-1. Prohibition of bribery
Such actions shall be prohibited as to give money or other benefits to or receive thesame from a public servant and/or a person with a similar capacity (hereinafter referredto as a “public servant, etc.”) or promise or offer the same to a public servant, etc., witha view to receiving unfair favors.
1-2. Prohibition of bribery through a third party
Such actions that fall under the actions of bribery of the preceding article shall be
prohibited even through an agency, consultant, customer, business partner, familymember, friend or any other third party.
1-3. Facilitation payment
In some countries or regions, there are cases where a small amount of paymentthat has no legal grounds (hereinafter referred to as a “facilitation payment”) is
demanded by a public servant, etc., to expedite or facilitate normal administrative
procedures. However, in principle, such a facilitation payment shall be prohibited.
1-4. Measures to be taken in case of violation
In the case of a violation of these Guidelines or the laws and regulations
concerning bribery of each country, a penalty may be applied based on the internal
rules or the relevant regulations. In addition, when having actually identified a violation
or recognized an act suspected of a violation, a prompt report shall be made to thedivision in charge of legal affairs or compliance of the relevant company of theCompany Group.

-1-2. Matters to be addressed by the Company
2-1. Records management
To ensure compliance with the laws and regulations on bribery and theseGuidelines, each company of the Company Group shall record all payments andreceipts in terms of its transactions and endeavor to establish and maintain a system forthe appropriate preservation thereof.
2-2. Enlightenment activities
Each company of the Company Group shall provide education and training forprotection against bribery as may be necessary to improve the understanding of thelaws and regulations on bribery and these Guidelines.
2-3. Protective measures against bribery through a third party
To prevent an unintended act of bribery by a third party, each company of theCompany Group shall, as may be necessary, implement an appropriate screening whenemploying a third party and take such measures as to impose on said party theobligation not to engage in bribery by means of a contract, a written pledge, etc.

3. Other
3-1. Relationship between these Guidelines and the Regional Guidelines
The guidelines specifically established by a region or each company may not
conflict with these Guidelines and in the event of any inconsistency with the content ofthese Guidelines, these Guidelines shall prevail.
3-2. Revision of these Guidelines
Revisions of these guidelines shall be drafted by the General Manager of theGeneral Affairs Department of the Company, and after approval by the Compliance
Officer of the Company, such revisions shall be enacted through a decision by the Risk
Management Officer of the Company.
Established on March 25, 2016-2-