Nikon Anti-Bribery Policy
Nikon proves worthy of the trust given by society under its corporate

Established April 21, 2014

prohibits the accepting or requesting of improper Benefit.

philosophy "Trustworthiness and Creativity", and has clarified its zerotolerance approach against bribery.
By establishing this policy, Nikon will fulfill its group-wide commitment to
the prevention of bribery in all countries and areas where it conducts
business, to enhance the relationship of trust with society.
- ScopeThis policy applies to all directors and employees of Nikon ("Employees").

2. Dealing with Public Officials
Nikon will never provide, offer or promise bribes to public andquasi-public officials (including but not limited to officers or staff ofnational or local governments, government-controlled enterprises,
government-controlled hospitals, political parties, etc., "Public Officials").
Nikon will conduct its business activities in compliance with applicableanti-bribery laws and regulations of relevant countries.

Nikon mentioned herein refers to Nikon Corporation and its subsidiaries.
3. Dealing with Third Parties- Responsibility

Nikon will never provide, offer or promise bribes to Public Officials

Responsibility for compliance with this policy is with top management who

through third parties such as agents and / or consultants. Nikon will selectwill immediately investigate the facts, and take appropriate actions, should

and assess the third parties from the perspective of anti-bribery

any violations or potential violations of this policy occur.

compliance before starting business transactions, and requests theirpledges against bribery when necessary. When undertaking investment

1. Prohibition of Bribery
Nikon prohibits the providing, offering or promising of money, benefit orother advantage ("Benefit"), directly or indirectly, to another person orentity, for the purpose of securing an improper advantage. Nikon also

Nikon Anti-Bribery Policy

activities, Nikon will perform due diligence including evaluation of bribery
risks, of target companies in merger and acquisition transactions orprospective joint venture partners.

Nikon Anti-Bribery Policy
4. Accurate Record-Keeping
Nikon will keep accounting books accurately based on facts and maintainrelated vouchers appropriately, under its sound internal control system,
to demonstrate its compliance with this policy and applicable anti-bribery
laws and regulations of relevant countries.

regulations of relevant countries may result in disciplinary actions by therelevant Nikon group company, and may also result in such other action,
including legal action, by appropriate government authorities.
8. Revision or DiscontinuanceThis policy is drafted by the chairperson of the Nikon Compliance

5. Risk Assessment and Guidelines
Nikon will assess the bribery risks facing its business as appropriate, andreview this policy when necessary. In addition, regional or individualcompany guidelines will be established by relevant group companies
based on this policy.
6. Training and Reporting
Nikon will communicate this policy and applicable guidelines to
Employees through education and training, and will require Employees tocomply with them. Nikon will develop a reporting framework in order toprevent or correct any violations of this policy or applicable guidelines.
7. Consequences of Violation
Violation of this policy and / or applicable anti-bribery laws andNikon Anti-Bribery Policy

Committee and approved by the Executive Committee.