Kirin Group Anti-Corruption Policy
The Kirin Group shall fully understand and comply with the laws and guidelines of thecountries and regions where it conducts businesses, and shall not tolerate, directly or indirectly,
any involvement in corrupt practices* at any time. This Policy, which sets forth the basic
attitude and actions to prevent corrupt practices, shall apply to all executives and employees
working for the Kirin Group. In addition, all business partners and agents of the Kirin Group arealso required to comply with this Policy.
(*) "Corrupt practices" in this Policy refers to any act of abusing authority to gain an unfair
advantage, including bribery, facilitation payments to gain an unfair advantage, giving orreceiving excessive entertainment or gifts, embezzlement such as the improper receipt ofkickbacks or rebates, unfair competition such as bid-rigging or collusion, extortion, fraud, andmoney laundering.
1.

Organizational structure to prevent corruption
The Kirin Group shall ensure that all executives, employees, and related parties, including
business partners and agents, are fully aware of this Policy, and shall establish therequired system for anti-corruption compliance.
-We shall establish departments in charge of compliance and whistleblower hotlines forthe prevention of corruption, and shall strive for equality and fairness in their operation.
-We shall establish a system for promptly consulting with and reporting on any acts orsuspected acts in violation of all applicable anti-corruption laws, agreements, guidelines,etc. in each country and of this Policy.
-We shall stipulate the "Kirin Group Sustainable Supplier Code of Conduct" which reflects
this Policy, and shall strive to prevent indirect involvement in corrupt practices by making
acceptance of the Code a precondition for transactions with business partners, agents,and others.
-In the event of understanding of a suspected violation of this Policy, we shall promptly
investigate the facts and take appropriate measures.

2.

Education and training
The Kirin Group has prepared the Group Compliance Policy, the Group Compliance
Guidelines, the Group Anti-Bribery Rules, and the Rules on the Establishment andOperation of the Kirin Group Whistleblower Hotline, in addition to this Policy, and has
made them available to the entire Group at all times through internal notifications, theintranet, and other means.
The Kirin Group shall continue to provide ongoing education and training on a regularbasis to its executives, employees, and related parties, including business partners andagents, in order to further disseminate ethical awareness and to maintain and improve its

anti-corruption system.
3.

Proper accounting procedures and records
The Kirin Group shall, in order to fulfill its accountability for compliance with theanti-corruption laws and guidelines of each country and with this Basic Policy, keep factualand accurate records of all authorized documents, accounting books, etc., relating toexpenditures, and properly store related reports under an appropriate system of internalcontrols.。

4.

Monitoring and continuous improvement
The Kirin Group shall conduct periodic self-inspections and internal audits of its
anti-corruption initiatives and compliance status in accordance with the risks in each
deployed country and its business to confirm that the anti-corruption system isfunctioning properly. On the basis of the results, the Kirin Group will revise and improve
this Policy and its compliance procedures as necessary.

5.

Establishment and operation of whistleblower hotlines
TheKirinGroupshallestablishawhistleblower

hotlinefor theprompt

consultation and reporting of any acts or suspected acts in violation of all
applicable anti-corruption laws, agreements, guidelines, etc. in each country an dof this Policy.
The Kirin Group shall conduct a fair investigation, working with the whistleblower
to confirm the facts and resolve the actual problem. It shall strive to prevent any
disadvantageous treatment or reprisals against whistleblowers or person s whocooperate in investigations.

6.

Measures and penalties
The Kirin Group shall refuse to continue transactions with any business partner or agent in
the event that it becomes aware of any form of corrupt practices by said partner or agent.
The Kirin Group shall strictly and promptly punish executives and employees who violate
anti-corruption laws and regulations or this Policy, in accordance with the internal rules
and work regulations of each Group company.

＜Revised in March 2023＞