Meiden Group

Anti-Bribery Policy

June, 2020Compliance Committee

Foreword
We, Meidensha Corporation, established the Meiden Group Corporate Codeof Conduct and are proactively engaged to ensure its regulatory compliance.
Within the Meiden Group Corporate Code of Conduct, we display our attitude
towards the prohibition of Bribery by establishing a strict code with regard togift-giving and business entertainment, and by demanding compliance withall applicable laws and regulations, as well as, other social rules.
To ensure compliance with the Anti-Bribery Laws and Regulations and topromote appropriate business activities, this Policy (hereinafter referred to as“this Policy”), establishes a more specific code based upon the prohibition ofBribery stipulated within the Meiden Group Corporate Code of Conduct.
Each company within the Meiden Group and all their members shall take theappropriate measures to comply with this Policy and the Anti-Bribery Lawsand Regulations related to our business activities.
Compliance with this Policy also requires keeping our promise to society,which earns and builds trust with our clients and society. Please ensure you
fully comprehend this Policy and continue to conduct business activities in
the appropriate manner, while realizing the successful development of theMeiden Group.

June, 2020

Takeshi Miida
President

Meidensha Corporation

【 Meiden Group Anti-Bribery Policy 】

1 Prohibition of Bribery(1) ‌All members of the Meiden Group shall not engage in any act of Bribery towards“Public Officials” ※ 1 of a country or region where the Meiden Group conducts
business or towards a Meiden Group client (either a private business entity
or individual) for the purpose of obtaining or retaining improper advantages inbusiness activities.
(2) ‌In this Policy, “Bribery” means taking an action (or providing an inappropriatebenefit), to an entity or an individual, which is illegal, unethical, or a breach oftrust, or requesting an entity or an individual to take such action (or to provide
an inappropriate benefit), in return for, directly or indirectly ※ 2, offering, providing,promising, requesting, or accepting money, gifts, business entertainment,
donations, services, employment, and/or any other advantage (including anythingof value, regardless of whether it is tangible or intangible) to/from such entity orindividual, with dishonest intent or purpose.
※１ ‌The term “Public Officials” generally refers to a business entity or individual exemplified
below from ① through ④ . Provided, however, that each individual and specific case should
be judged in accordance with the provisions of the applicable Anti-Bribery Laws andRegulations.
‌A person who is in a legislative, administrative, or judicial position①‌An administrative agency (an organization established based on laws and ordinances in②
order to conduct business relating to the public interest) and its staff members③ ‌A public corporation and its staff members④ ‌A staff member of a public international organization or an entity or an individual who isdelegated a work assignment by a public international organization※２ “Bribery” includes any action taken via a third party, including a business partner.

2		 Compliance with Laws and Regulations
All members of the Meiden Group shall comply with all laws, ordinances, andregulations, established or stipulated to prevent Bribery, that are applicable within
the countries and regions where the Meiden Group conducts business (hereinafterreferred to as “Anti-Bribery Laws and Regulations”).

3 Record Management
The Meiden Group properly processes, prepares, and retains accounting books andrecords with respect to all transactions, expenditures, and dispositions of assets, incompliance with internal rules and procedures.

4 Whistleblower System(1) ‌The Meiden Group establishes and maintains a contact desk for consultation orto report any activity that violates or appears to violate the applicable Anti-Bribery
Laws and Regulations or this Policy (hereinafter referred to as “Violation”).
(2) ‌In the event a Meiden Group member witnesses or learns of a Violation, themember shall immediately report such Violation to their boss, the contact desk, oranother appropriate channel.
(3) ‌The Meiden Group prohibits any act of retaliation against any whistleblower thatsincerely utilizes this reporting system by reporting a Violation to a complianceofficer or the contact desk.
(4) ‌In the event the Meiden Group discovers a Violation, the Meiden Group shallconduct a proper investigation and take appropriate action to correct suchViolation.

5 Punishment
Any Meiden Group member who violates the applicable Anti-Bribery Laws andRegulations or this Policy shall be subject to disciplinary action imposed incompliance with the disciplinary provisions of the company that employs the member.

6 Efforts of Meiden Group Company
Each company within the Meiden Group, based on this Policy, shall establish andmaintain the necessary preventive provisions, systems, and procedures in order toprevent Bribery. Furthermore, in order to ensure continued compliance with the AntiBribery Laws and Regulations and this Policy, each company within the Meiden
Group shall take necessary and appropriate measures, such as conducting ongoingeducational training for its members.
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