PoliciesAnti-Bribery Policy

1. Purpose

The Nisshin OilliO Group establishes this Policy to ensure compliance with the provisions set out in “2. Fair business practices and anticorruption” under “IV. Action with a Sense of Mission as a Member of Society” in The Nisshin OilliO Group Code of Conduct. This Policy applies both domestically and internationally. Notably, the laws, regulations, business practices, and social norms of each country also apply.

2. Fair business practices and anticorruption

• (1) We will maintain a fair and equal stance toward suppliers of raw materials and other materials at all times and will not unjustly disadvantage our suppliers by capitalizing on a superior position. We also will not request the provision of personal benefits or convenience.
• (2) We will maintain a fair and equal stance toward distributors at all times and will not engage in any improper conduct, such as exclusion, unjustly discriminatory treatment, or interference in business activities.
• (3) The exchange of hospitality and gifts with business partners does not deviate from the scope of sound business practices and social norms. We will also not provide hospitality or gifts for improper purposes, including to obtain advantages by excluding competitors.
• (4) We will not extend or receive any bribery, benefits, conveniences, gifts, or other treatment lacking reasonable grounds to or from domestic and international parliamentarians, local government heads and assembly members, and officers and employees of government agencies and local governments.
• (5) We will not make small payments intended to facilitate or expedite administrative procedures (facilitation payments) unless explicitly permitted by the laws and regulations of the country in question.
• (6) We will not allow agents or other third parties to engage in any conduct that violates these rules.

3. Recording and retaining transaction details

To demonstrate compliance with anti-bribery regulations in each country and with this Policy, we will accurately record expenditure approvals, accounting records, and other relevant records based on facts, and properly retain related ledger sheets.

4. Whistleblowing system

To prevent corruption and detect it as soon as possible, we will accept through this whistleblowing system consultations and reports from all officers and employees regarding any conduct that violates or may violate this Policy. We will operate the whistleblowing system appropriately to ensure that whistleblowers are protected from disadvantageous treatment and maintain the confidentiality of the information they provide.

5. Disciplinary action

If an officer or employee violates anti-bribery laws and regulations or the Company’s policies for preventing bribery (including this Policy), the individual will be subject to strict disciplinary action in accordance with internal rules, such as workplace regulations, in addition to personal legal liability.