GLOBAL ANTI-BRIBERYPOLICY

BRIDGESTONEINTEGRITY
IN THE MARKETPLACE
Policy at a Glance
Introduction

4

Policy Statement and Application

4

What is Bribery?

6

Gifts, Meals, Entertainment and Travel

8

Dealings With Third Parties

10

Facilitating Payments

12

Political Contributions

13

Charitable Contributions

13

Books and Records

14

Audits14

Reporting Concerns or Potential Violations

15

Bridgestone Global Anti-Bribery Policy

3Introduction

Policy Statement and Application

The Bridgestone Code of Conduct is inspired by Bridgestone’s

The Purpose of This Policy

Mission and aligned with the Bridgestone E8 Commitment, andprovides practical guidance for handling many of the ethicalissues you may face as a Bridgestone employee.

The Bridgestone Global Anti-Bribery Policy reaffirms Bridgestoneʼs

for the joint venture and abide by the principles of this Policy

operations. Remember, our suppliersʼ reputation and behavior

in their own operations.

can directly affect Bridgestone. Only do business with companies

stance on bribery and corruption as described in the Code of

Bridgestone companies may have local policies with content that

Conduct. This Policy also provides practical guidance and describes

overlaps with this Policy. If a local policy is less restrictive than

Bridgestoneʼs requirements regarding the prevention of bribery

this Policy, this Policy shall apply. This Policy cannot, of course,

and how to address bribery risks.

cover every situation. It is not a substitute for good judgment

As a global company, Bridgestone must comply with all applicableanti-bribery laws. These laws typically include prohibitions on
bribing Government Officials and any other third party, books
and records requirements, and criminal and civil penalties forviolations.

POLICY STATEMENT
Bridgestone strictly prohibits all forms of bribery. Under nocircumstances may a Bridgestone employee or any third
party acting on Bridgestoneʼs behalf offer, provide, receiveor accept anything of value to or from anyone, including a
Government Official, to obtain or retain business or for any
other improper advantage.

and common sense. You are encouraged to contact a memberof the Law Department if you have any doubt about the legality
or ethics of a course of action, or just want to understand thelegal risks involved.

This Policy applies to employees of all Bridgestone companies
across the globe, including joint ventures that we control,
and any third party acting on Bridgestoneʼs behalf. Where weparticipate in, but do not control, a joint venture relationship,
we will encourage our partners to adopt similar requirements

4with our commitment to compliance and ethics.

Consequences of Non-Compliance
Violations of anti-bribery laws can result in serious consequencesfor Bridgestone and the individuals involved, including criminal andcivil penalties and even imprisonment. Bridgestone is committed
to compliance and takes violations of this Policy very seriously.
Failure of any employee to comply with this Policy may result in

Our Responsibilities as Employees
As Bridgestone employees, we all must:

disciplinary action, up to and including termination. Furthermore,
the business relationship with any Intermediary that fails tocomply with this Policy will be subject to termination.

• Demonstrate integrity in all we do.
• Familiarize ourselves with and follow the Code of Conduct,
this Policy and other company policies that may apply in our
locations to ensure compliance with all applicable anti-bribery
laws and protect Bridgestone’s assets and reputation.
• Contact the BridgeLine or speak to any person listed in “Where
to Go For Help” in the Code of Conduct regarding possible
Code or policy violations or other ethical concerns.

Application of This Policythat comply with the law and understand and operate consistently

Our Dealings with Suppliers
The rules and expectations set forth in this Policy also serve as a

Terms We Use
The term “employees” also includes directors and officersof Bridgestone companies.
“Intermediary” includes any agent, consultant, distributor,
lobbyist, transportation or logistics provider, customs
clearing agent, broker, and joint venture partner or any otherthird party representative acting on behalf of Bridgestoneor who acts jointly with Bridgestone.

set of expectations for our suppliers. Furthermore, Bridgestone
has specific procurement policies, including the Global Sustainable
Procurement Policy, which establish requirements for supplierThis Policy is a living document and may be updated periodically.

Bridgestone Global Anti-Bribery Policy

5What is Bribery ?
Bribery is a form of corruption that violates the trust of the public
and our customers, threatens economic and social development
and runs counter to Bridgestoneʼs values and culture. Although
you must never offer or receive bribes to or from anyone, in many
countries you must be especially vigilant not to engage in any
form of bribery with Government Officials.
Remember, it is your responsibility to understand whether
someone you are dealing with is a Government Official. If you
are unsure, you should seek assistance from the Law Department.

Terms We Use
A “bribe” is the giving or offering anything of value, either
directly or indirectly, to any person, to induce the recipient
to misuse their position or to obtain or retain any improper
advantage.
“Anything of value” is broadly defined. It can include
practically any form of benefit such as cash or cash equivalents(e.g. gift cards or gift certificates), gifts, commissions, meals
and entertainment, travel expenses, use of vacation homes,
favors such as educational or employment opportunities forfriends and relatives, donations to designated charities,
discounts, loans, political contributions, the favorable
outcome of a government action, and a decision to award
or continue business.
The definition of “Government Official” is very broad. It
includes a government employee (including employees ofregulatory agencies, departments and other public bodies
such as public universities), a political party candidate or
employee, an employee of a state-owned or controlled
enterprise, an employee of a public international organization(e.g. the United Nations, World Bank, or World Trade
Organization), any member of a royal family, any judge,
court staff or member of the judiciary system, and anyone
acting in an official capacity on behalf of a national, stateor local government entity.

6

7

Gifts, Meals, Entertainment
and Travel

General Requirements for Gifts,
Meals and Entertainment

The exchange of gifts, meals, entertainment, and travel withAt Bridgestone, we cannot allow the exchange of gifts, meals,

customers, suppliers, and other business partners can be an

entertainment, or travel to improperly influence, or appear toimportant part of building goodwill and developing relationships.
In many countries, it may also be an accepted and appropriate

General Requirements
for Travel

Key Requirements

Under some circumstances, it may be acceptable for Bridgestone

improperly influence, our independent business judgment or the

Whenever you are considering offering, accepting, oror other business partners.

independent business judgment of the recipient. If you engage

providing any gift, meal, or entertainment, you must ensurebusiness custom. This practice, however, can sometimes create

in any of these activities, you should be aware that the company

that the following criteria are met:

compliance risks and, if conducted inappropriately, could violate

has requirements and procedures that must be followed.

applicable laws and company policies.

If you are ever in doubt as to the appropriateness of these activities
or whether they conform with company policies or applicable law,
you should seek assistance from the Law Department.

• It is related to a legitimate business purpose;• It is infrequent and reasonable in amount under thecircumstances;• There is no expectation that it is being given in exchange
for a favor or undue business advantage;• It conforms with our Code of Conduct, applicable law
and any other policies or procedures in your location;• It would not embarrass either Bridgestone or therecipient if details are made public; and• It is properly reported and documented in the companyʼsbooks and records.

to provide travel and accommodation to customers, suppliers,

Key Requirements
If you are considering offering or providing payment of any
travel-related expenses for a customer, supplier, or business
partner, you must ensure that the following criteria are met:
• It is related to a legitimate business purpose suchas the promotion, demonstration or explanation of
Bridgestone’s products or services, tours of our facilities,
or the performance of a contract;• It is infrequent and reasonable in amount under thecircumstances;• It is not given in exchange for a favor or undue businessadvantage;• It conforms with our Code of Conduct, applicable law

Due to the special risks associated with dealing with
Government Officials, you must obtain written approval fromthe Law Department before offering or providing any gift, meal,

and any local policies or procedures;• It would not embarrass either Bridgestone or therecipient if details are made public;

entertainment or anything else of value to a Government Official.

• No per diem cash is provided; andRemember, other companies also have gift, meal and• It is properly reported and documented in the company’s

entertainment policies. Be mindful of these policies and ask

books and records.

before offering such gifts and entertainment whether doing
so would violate any recipient ʻs company policy.

8

Bridgestone Global Anti-Bribery Policy

9Dealings With Third Parties
Bridgestone can be held responsible not only for bribes offered,

Due Diligence“RED FLAG” EXAMPLES

Appropriate commitments and targeted contractual provisions

so. Use great care when hiring and working with Intermediaries.

Bridgestone takes a risk-based approach to conducting anti-

Examples of “red flags” include the following:risks or other relevant information discovered in due diligence

Like Bridgestone employees, Intermediaries are prohibited frombribery due diligence. While the amount of time and effort

offering, providing, receiving or accepting anything of value torequired to complete the process will depend on various

or from anyone, including a Government Official, to obtain or

factors, the anti-bribery due diligence process will typicallyretain business or for any other improper advantage.

include the following:

paid or received by employees, but also when Intermediaries do

To help prevent bribery, you must always be aware of theactivities conducted by Intermediaries on Bridgestoneʼs behalfand stay alert to warning signs that may indicate potential
misconduct. To reduce the risk of bribes by an Intermediary, youmust act carefully when selecting and evaluating Intermediaries
and identify in advance any potential anti-bribery concerns that
may arise from the proposed relationship. This “anti-bribery due• Assessing the business justification, services andcompensation structure for the proposed engagement;• Collecting and evaluating information about theIntermediary and its ownership and management,
including business background, reputation, qualifications
and financial information;• Assessing any relationships with Government Officials;

diligence” is a critical component of our anti-bribery compliance• Following up on warning signs or irregularities; andprogram.

• Obtaining any required approvals in advance of anengagement.

• The Intermediary is, or has close family or business ties
to, a Government Official;• The Intermediary has been recommended by aGovernment Official, particularly one with discretionary
authority over the business at hand;• The Intermediary recommended by our business partner
does not have meaningful expertise or prior experiencein the field of work for which he is recommended;• The Intermediary requests a fee/commission that is
excessive or to be paid in cash;• The Intermediary requests unusual payment terms,
such as an up-front lump sum payment, payment to an
account in another party’s name, payment in a currency
that has no relationship to the transaction, or payment
in a third country, especially if it is a country with little
banking transparency;

Throughout the anti-briber y due diligence process and also
during contrac t per formance, it is impor tant to look out for“red flags” that may indicate that fur ther investigation is
warranted when selec ting or working with an Intermediar y.

should be used to help reduce identified risks, including any
findings, and the contractual provisions should be regularly
monitored to ensure the Intermediary is acting in accordancewith the contract. Additional measures and safeguards, including
compliance certifications and training, may also be utilized. Yourobligations of due diligence do not end once an Intermediary is
selected and engaged. You should carefully explain our complianceexpectations, continuously monitor the Intermediary’s activities
and stay alert to “red flags” to ensure continued compliancethroughout the engagement.
Due diligence is also critical in the context of new businessendeavors, such as acquisitions and joint ventures. Before entering
into any such endeavors, consult with the Law Department for
advice on appropriate due diligence and safeguards to mitigate
bribery risks.
To learn more about Bridgestone’s anti-bribery due diligenceprocess, please visit the compliance intranet site for your location• The Intermediary suggests that a particular amount ofor contact the Law Department. If you are in any doubt about how

money may be necessary to obtain business or “close

this Policy and our anti-bribery due diligence program applies to athe deal”;• The Intermediary requests reimbursement of extraordinary,poorly-documented, or last-minute expenses; andparticular business endeavor or the engagement of any particular
third party, or if you have any concerns about a prospective or
existing Intermediary, contact the Law Department for assistance.

• The due diligence notes the presence of unexplained
sub-contractors or vendors that the Intermediary
proposes to retain to assist with interactions with thegovernment.

10

Bridgestone Global Anti-Bribery Policy

Bridgestone Global Anti-Bribery Policy

11Facilitating Payments
Bridgestoneʼs prohibition on bribery applies to all improper
payments, including “facilitating” payments. Because suchpayments are a form of corruption, Bridgestone prohibits theuse of facilitating payments, even when such payments arecustomary locally.

Political Contributions
Terms We Use
A “facilitating payment” is a small payment made to a
Government Official to expedite or facilitate routine, nondiscretionary actions or services such as processing visas,permit or licensing applications, providing utilities, or theloading or unloading of cargo. Bridgestone prohibits the useof facilitating payments.

The laws of many countries set strict limits on, and in somecases prohibit, contributions by corporations to political parties.

Key Requirements

Bridgestone prohibits that company funds, resources, or facilities

If you are considering offering or providing a charitable

are used to support directly or indirectly any political party orcontribution, you must ensure that the following criteria

candidate, unless approved in advance by the Law Department

are met:and, where applicable, the Government Relations Department
or the relevant department that manages government relations
in your region, and provided it is made in strict accordance withyour regional and local policies.

• It is not offered, promised, or provided to obtain or
retain business or for any other improper advantage;• It conforms with Bridgestone policies, applicable law
and any local policies or procedures;• It is not made to a Government Official, and there is no

Charitable Contributions

indication that the contribution will be redirected to
an individual Government Officialʼs personal use; and• It is properly reported and documented in the companyʼsbooks and records.

As part of our corporate social responsibility commitment,
Bridgestone actively supports charitable causes in the communities
in which we operate around the world.

Any charitable contribution that is requested by a Government

From time to time, providing charitable contributions can create

Official, made to an organization associated with a Government

corruption risks for Bridgestone. Risks can arise in a variety of

Official, or made to a government entity must be approved inways, including where a charitable organization does not actuallyadvance by the Law Department.

exist, is a front or shell entity, or is associated with a Government
Official. As a result, it is important to conduct due diligence andexercise care when selecting charitable organizations and to
gain assurances that contributions will be used for the purpose
intended and will not be diverted to an improper beneficiary.

1213Books and Records

AuditsReporting Concerns orPotential Violations

To prevent attempts to conceal improper payments throughBridgestone regularly conducts audits of relevant Bridgestone

If you know or suspect that violations of this Policy may be

incomplete or false documentation, anti-bribery laws set forth

operations to help ensure continued compliance with this Policy

occurring or are about to occur, you must promptly report therequirements for maintaining books, records, and appropriate

and applicable anti-bribery laws. You must cooperate with, andmatter to the Law Department. Alternatively, you may report

Bridgestone prohibits retaliation when business conduct or ethicalinternal controls. Consistent with these laws, Bridgestone requires

never interfere with or obstruct, such audit activities.

the matter to the BridgeLine. Where permitted by law, reports

issues are reported in good faith. Use the following link to accessto the BridgeLine can be made anonymously.

the BridgeLine for your region:that its books and records must fairly and accurately reflect thecompanyʼs transactions and disposition of assets.

| The BridgeLine

https://www.bridgestone.com/responsibilities/bridgeline/

All Bridgestone employees are responsible for ensuring that they
comply with the books, records, and internal control requirements
applicable to their roles and responsibilities. This includes maintaining
records of all due diligence and relevant approvals required under
this Policy and ensuring that all payments and expenses are fairly
and accurately recorded in the companyʼs books and records.

14

15

Q&A
Q: I understand that “facilitating payments” (small payments

Q: I know it is against the law to make payments to Government

Q: A Government Official is planning to visit our facility to

Q: Does Bridgestoneʼs Anti-Bribery Policy only address bribery

made to Government Officials to expedite routine transactions)

Officials, but everybody tells me that it is the only way to get

conduct a routine audit of quality controls. Is it permissibleof Government Officials or does the prohibition also address

are prohibited by company policy. Are officially authorized

things done in this country. Can I get around this by hiring an

to provide the official with a meal during the visit?

bribery of any other parties?

fees, such as expediting fees for passport renewals or visa

agent who will pay the officials a commission?

A: Providing a meal to a Government Official visiting a company

A: Bridgestoneʼs Anti-Bribery Policy provides that all bribery isfacility is usually permissible as long as it is infrequent, the cost ofabsolutely prohibited. This includes commercial bribery whereapplications, considered “facilitating payments”?
A: Expediting payments made to a government agency (not to anindividual) that are officially authorized (such as a rush fee listed
on a government agency schedule to expedite the processing ofpassport renewals or visa applications) and are backed up with an
official government receipt are not “facilitating payments” and,accordingly, are generally allowed. Contact the Law Department
if you are unsure whether an expediting payment is appropriate
and legal.
Q: I know that bribery is prohibited, but what if a Government
Official (such as a police officer or immigration officer) threatens
to detain or harm me unless I give him or her a nominal cash
payment?

A: No. It is against the law to pay bribes to Government Officials
regardless of whether the payment is made directly or indirectly
through a third party. The consequences of making such payments
could be severe for both you and the company. You cannot getaround your or the company's legal responsibilities by hiring
agents to do what you are not permitted to do. Therefore, when
considering hiring an agent, appropriate due diligence must
be conducted to carefully assess the rationale for the hiring,whether the proposed fees are appropriate for the services tobe provided, and the background, reputation and qualificationsof the agent. Consult with the Law Department to learn more
about Bridgestoneʼs due diligence process.

the meal is reasonable and it is not provided with the expectation

Government Officials are not involved. Under no circumstancesof any return favor. In accordance with our Code of Conduct, no

may a Bridgestone employee or a third party acting on

gifts, entertainment or other items of value should be offered or

Bridgestoneʼs behalf offer anything of value to any third party,

given to a Government Official without the prior written approval

including governmental and non-governmental customers, orof the Law Department. You must also ensure that all other

their representatives, to obtain or retain business or for any othercompany policies and procedures, including those in your location,commercial advantage. Contact the Law Department if you need

are followed.

more information or guidance.

Q: A customer is asking for a payment that appears to be a bribe
but it is not clear whether the payment would be prohibited
under local laws. Can I make the payment?
A: Prior to making any such payment, you should contact the
Law Department to determine whether or not this payment is

A: Bridgestone recognizes that, in extremely rare situations, anappropriate and whether such payments might violate company

employee’s health or safety could be at risk if he or she fails topolicy, local laws or any other laws applicable to the company.

comply with such a request. If you feel your health or safety is in
imminent danger and, in your judgment, the best way to protect
yourself is to make the payment, company policy does not prohibit
you from making such a payment. These types of payments are
not bribes. As soon as you reach a place of safety, immediately
report the payment to your manager, the Law Department, and,
where applicable, the Security Department. The payment mustalso be properly reported and documented in the company's
books and records.

16

Bridgestone Global Anti-Bribery Policy

Bridgestone Global Anti-Bribery Policy

17

APPROVED BY:
CHRISTOPHER NICASTRO
VICE PRESIDENT AND SENIOR OFFICERGROUP GLOBAL GENERAL COUNSELBRIDGESTONE CORPORATIONHIDEKAZU KIMIZUGROUP GLOBAL GENERAL COUNSELVICE PRESIDENT AND SENIOR OFFICERRESPONSIBLE FOR CORPORATE ADMINISTRATION,
CHIEF COMPLIANCE OFFICER
BRIDGESTONE CORPORATIONAPPROVAL DATE: NOVEMBER 2023