PILOT Group (hereinafter referred to as “the Group”) has established this Policy with the aims of seeking to prevent all forms of corruption including bribery, acting in good faith with a high level of morality, and gaining the trust of society. To achieve these aims, the Group will comply with the laws and regulations on bribery, etc. applicable in the countries and regions where it conducts business and with this Policy, and has established the following specific measures and standards of conduct.
Prohibition of Corruption and Bribery
1.Prohibition of Bribery
The officers and employees of the Group will not offer, promise, provide, or receive any bribe, whether directly or indirectly, to or from any person.
2.Prohibition of Entertainment, Gifts, etc. to Public Officials and Similar Persons
The officers and employees of the Group are prohibited from improperly providing or promising money, gifts, entertainment, or other benefits (including facilitation payment) to public officials and those equivalent thereto to gain transactions or unjust benefits.
3.Establishment of Sound Relationship with Clients
The Group conducts transactions only with clients that comply with laws and regulations and endeavors to introduce clauses prohibiting bribery and other corrupt practices in agreements with these clients.
4.Maintenance of Fair and Free Competition
The Group complies with the relevant laws and regulations including the Antimonopoly Act, will not abuse its superior bargaining position to cause any disadvantage to clients, and will not engage in any act that impedes fair transaction and fair competition.
5.Discontinuation of Relationship with Antisocial Forces
The Group prohibits any inappropriate provision and receipt of benefits and will not have or use any relationship with antisocial forces and other organizations that threaten the order and safety of civil society. The Group will reject any violent or unreasonable demand from antisocial forces and will not provide any funds to them or be involved in any money laundering or similar conduct.
Management of Clients, etc.
The officers and employees of the Group inform clients, etc., before commencing a transaction, of their position of not permitting bribery or other corrupt practices.
The Group conducts a review of clients, etc. before a business relationship is established with them. In the event of acquisition, merger, joint venture, or other similar case, the Group conducts a prior assessment of the risk of corruption, including bribery, associated with the other party.
Accounting Records
The Group prepares accurate books and records for all transactions in reasonable detail and maintain records in accordance with the regulations and rules of each company of the Group.
Compliance System
The Group thoroughly notifies officers and employees of this Policy, has established a framework for compliance with the laws and regulations on bribery and prevention of corruption, and applies this Policy to all officers and employees of the Group. In the event of any violation of the relevant laws and regulations and this Policy, the violating party is subject to strict punishment in accordance with the internal regulations and rules of each company of the Group. If any of the officers and employees of the Group is suspected to be in violation of the relevant laws and regulations or this Policy, we have established a system whereby consultation and reporting is promptly made to the department in charge of compliance designated by each company of the Group. The Group has established a whistleblowing system that ensures anonymity in relation to breaches of this Policy and prohibits retaliation against a person who has reported a breach.
Audit/Risk Assessment
The Group periodically assesses the risks of bribery or other corrupt practices and appropriately addresses those risks. The Group periodically reviews this Policy and the compliance status therewith and revises and improves it as necessary.