Governance System

Basic Anti-Bribery Policy

Working in line with its corporate principle of being “Active and Steadfast,” Morito and its subsidiaries (collectively, the “Morito Group”) address anti-corruption under the Morito Group Basic CSR Policy.
The Morito Group has established this policy in order to implement anti-bribery measures and will make group-wide efforts to prevent bribery.

1Prohibition of bribery

1. The Morito Group will not engage in any of the acts described below.
2. (1) Bribery of public officials
   Providing, promising, or offering money or other benefits directly or indirectly to public officials or other persons in a position of a public nature (“public officials”)with the intention of influencing the performance of their duties, or authorizing an employee, etc. or a business partner to engage in such acts, whether in Japan or abroad
   *Public officials include the following persons.
   
   • 1. Employees of national and local governments of Japan or other countries
   • 2. Officers and employees of government-affiliated companies and corporations in Japan or other countries
   • 3. Officers and employees of corporations who are deemed equivalent to public officials by law in Japan or other countries
   • 4. Officers and employees of international organizations
   • 5. Officers and employees of businesses that have been delegated authority by national or local governments of Japan or other countries or international organizations
   • 6. Officials of a political party
   • 7. Candidates for public office
   • 8. Persons equivalent to 1 through 7 above
3. (2) Bribery of non-public officials
   Providing, promising, or offering money or other benefits directly or indirectly to officers or employees of other business operators (whether a legal or natural person) with the intention of causing them to perform illegal or fraudulent acts in their official capacity in order to obtain or maintain a business advantage, or authorizing an employee, etc. or a business partner to engage in such acts, whether in Japan or abroad
   
4. (3) Bribery
   Demanding, promising to accept, or accept money or other benefits from other business operators or public officials as consideration for providing a business advantage, whether in Japan or abroad
   
5. (4) Aiding and abetting bribery or participating in a conspiracy
   Aiding or abetting bribery or participating in a conspiracy concerning bribery

2Strict management of accounting records

The Morito Group records all transactions accurately in its books of account and appropriately maintains relevant documents so that it can prove that bribery has not taken place.

3System to prevent bribery

1. (1) Communicating anti-bribery policy and ensuring compliance
   The Morito Group has established the Compliance Rules and the Anti-Bribery Rules for the entire group and ensures that all employees follow them. We also provide employees with training to help them gain a better understanding of the rules.
2. (2) Compliance Committee
   The Compliance Committee, chaired by the representative director and CEO, meets at least once a year to identify, scrutinize, and periodically evaluate bribery and other risks with an eye to continuously improving the system to prevent bribery.
3. (3) Whistleblower program
   The Morito Group has established the Whistleblower Program Rules with the aim of early detection and correction of illegal, fraudulent, or unethical acts, such as bribery, occurring within the group. We have set up a point of contact so employees who become aware of such acts can report them, as well as an appropriate system to protect employees who report such acts and disciplinary actions for violators.
4. (4) Internal audit
   The Internal Audit Department conducts audits in accordance with the Internal Audit Rules so it can manage the risk of bribery as well as other types of fraud and ensure that day-to-day operations are executed appropriately.

4Compliance request to business partners

We ask our business partners to ensure that their officers, employees, etc. as well as suppliers are fully aware of the intent of this policy.
If they become aware of any violation or suspect a violation of this policy or related laws and regulations, we ask that they promptly contact any of the Morito Group companies they do business with and cooperate fully in any investigation by either the Morito Group or relevant authorities.

Established on June 1, 2023