Group Shared Policy on Bribery Prevention

Ajinomoto Group
Established on : June 22, 2016
Revised on: August 1, 2019

Article 1（Purposes）

This policy is set forth to ensure thorough compliance with all applicable laws and regulations prohibiting bribery, and to prevent bribery committed by each company of Ajinomoto group and its officers and employees, thereby complying with the laws and regulations prohibiting bribery of each country and contributing to fair and ethical business activities.

Article 2（Scope of Application）

The scope of application of this policy shall be Ajinomoto Co., Inc. and its subsidiaries and officers (including any person equivalent thereto) and employees thereof (including employees who are employed for a fixed term, such as temporary employees and part-time employees) (collectively, the “Officers and Employees, etc.”)

Article 3（Compliance with Laws and Regulations)

The Officers and Employees, Etc. shall comply with this policy and the laws and regulations prohibiting bribery in the relevant countries and nations.

Article 4（Prohibition of Bribery of Public Officials and Facilitation Payments）

  1. The Officers and Employees, Etc. shall neither give nor offer or promise to give any bribes to public officials or any person equivalent thereto (including domestic public officials, foreign public officials, any person engaged in the public service of international organizations and the officers and employees, etc. of companies which are substantially controlled by the domestic state or foreign state or nationʼs governments or local public entities; collectively, the “Public Officials, Etc.”).

* Under laws and regulations prohibiting bribery in some countries and nations, staff who are appointed or designated by the government or the candidates thereof and royal families may also be considered public officials.

  1. Bribery means money or other benefits given, offered or promised to be given for the purpose of (a) inducing the Public Officials, Etc. to do or omit to do any act regarding their duties, or (b) exerting influence to cause other Public Officials, Etc. to do or omit to do any act regarding their duties, by using the positions of the Public Officials, Etc. in order to obtain or maintain businesses, or to obtain or maintain unfair profits. Money or other benefits include money, gifts, entertainment, and expenditure of expenses upon invitation.

  2. Small payments made for civil servants, etc., for the purpose of facilitating and speeding up routine administrative procedures (facilitation payments) are prohibited unless expressly permitted by local laws and regulations of the countries or regions in which Ajinomoto Group companies are located. Nevertheless, if the individual safety of the Officers and Employees, Etc. is at risk, personal safety shall be given top priority.

Article 5（Appointment of a Third Party）

  1. The Officers and Employees, Etc. shall notify the third parties subcontracted or appointed in connection with the businesses related to the Public Officials that Ajinomoto Group is in a position never allowing any violation against bribery in entering into business relationship with them.

  2. Each company of Ajinomoto Group shall conduct investigation and evaluation (due diligence) on whether or not the third party in the preceding paragraph is appropriate as a business partner before the business relationship is established.

Article 6（Accounting Records）

The Officers and Employees, Etc. must maintain accurate books and records with reasonable specificity on all company transactions. This principle must apply to all transactions, and particular attention must be paid to expenditures related to the Public Officials, Etc. to ensure appropriate handling thereof.

Article 7（Legal Compliance System）

  1. Presidents of each company of Ajinomoto group shall have the Officers and Employees, Etc. of each company comply with this policy.

  2. If there is any doubt regarding the interpretation etc. of this policy, the Officers and Employees, Etc. shall consult with the department in charge of risk management, officers in charge of risk management, or the department in charge of legal affairs at companies to which he/she belongs, parent company or Ajinomoto Co., Inc., or the Regional Headquarters of Ajinomoto Co., Inc. in charge of the company to which he/she belongs.

  3. The Officers and Employees, Etc. of the companies to which a whistle-blower system applies, may indicate a violation of this policy by using the whistle-blower system, and retaliation against any person who indicated the violation shall be prohibited.

Article 8（Audit）

Ajinomoto group shall include an audit regarding the compliance and execution of this policy and the provisions related to this policy in its audit procedures. Ajinomoto group shall periodically conduct such audit. The subject of the audit and audit procedures shall be determined by considering the characteristics of the country, region, company and its businesses, and the degree of risk.

Article 9（Penal Provisions and Disciplinary Punishment）

The Officers and Employees, Etc. who violated the laws and regulations or the rules of the company including this policy may be subject to disciplinary punishment including dismissal by the company to which he/she belongs, in addition to being subject to criminal, administrative or civil responsibility as an individual.