Anti-Corruption Policy

The Tsurumi Group rejects all forms of corruption, including bribery of public officials and individuals in the private sector both in Japan and overseas, as well as extortion, improper donations, facilitation payments, ties to anti-social forces, and insider trading. At the same time, we endeavor to prevent corruption to maintain sound and sustainable corporate activities.
All the executives and employees (including part-time, contract, and dispatched employees) of the Tsurumi Group are working to prevent corruption by complying with the relevant laws and regulations and acting in accordance with our Code of Conduct and rules. Together with this, we encourage our business partners to similarly strive to prevent corruption.
The Tsurumi Group has established whistleblowing desks both in Japan and overseas. Under these desks, we have set up a structure to promptly discover, address, and rectify actions suspected of violating laws, regulations, or the Articles of Incorporation within the Tsurumi Group. We strictly maintain the confidentiality of reports and do not tolerate any form of retaliation against whistleblowers. We also preserve anonymity as much as possible.
The Tsurumi Group provides anti-corruption training to our employees and disseminates information via internal communications. We offer additional training to high-risk divisions, such as those involved in public sector projects.
The above policy has been approved by the Board of Directors and communicated to all of our executives and employees.

Anti-Corruption Structure and Initiatives

The Tsurumi Group integrates anti-corruption measures into our compliance structure and promotion activities. In terms of our structure, the Compliance Management Committee and the Sustainability Strategy Committee address the issue relating to anti-corruption, leading to the establishment of a structure and the formulation of measures based on the external and internal situations. As part of our efforts, we have established policies and internal systems, and incorporated basic anti-corruption matters, policies, and internal systems, into our compliance program. Through this program, we provide training and ensure awareness to prevent corruption.
Please take a look at the compliance section on our website to learn about our compliance promotion governance structure, whistleblowing system, and compliance training.

Matters Relating to Anti-Corruption in Our Group’s Code of Conduct (Excerpt)

• Compliance with Applicable Laws and Regulations etc.

  In every aspect of our corporate activities, we shall comply with all applicable laws and regulations, community rules and in-house regulations, including this Code. We shall strive to ensure that all our corporate activities comply with internationally accepted norms, social ethics and normal business practices. (Code of Conduct II. 2)

• Fair and Free Competition

  The Tsurumi Group shall conduct fair transactions with all business partners, based on the principle of free competition and in compliance with anti-trust and fair trade laws and other applicable laws and regulations. We shall not engage in any action that inhibits fair and free competition, including collusion, nor shall we participate in meetings or in exchanges of information that may restrict free competition or engage in any activity that may be construed as doing so. We shall always maintain open and fair relations with our customers, business partners and competitors. We shall also carry out commercial transactions with integrity, by adhering to social ethics. (Code of Conduct IV. 3)

• Anti-Corruption

  The Tsurumi Group shall comply with all laws and regulations relating to donation. Prior to making any donation, we will investigate the organization to which we are considering a donation and how our donation will be used, and will carefully consider the necessity and appropriateness of any proposed donation. We shall comply with all laws and regulations relating to political contributions and political activities, including the Political Funds Control Act and the Public Offices Election Act, and shall only participate in such activities - including contributions - as permitted by law.
  The Tsurumi Group shall adhere to sound business practices and social norms when providing or receiving entertainment or exchange gifts with business partners or others. We shall not offer bribes to officials of public organizations (including former officials). In addition, we shall not provide any benefits to gain unfair business advantage, or offer entertainments, gifts or any other treatment that lacks justifiable grounds. (Code of Conduct III. 2 / IV. 4)

• Establishment and Operation of Internal Reporting System

  The Tsurumi Group shall establish and maintain effective internal reporting systems, so as to encourage members to promptly report any acts that are or may be in violation of this Code, and so as to ensure that reported incidents are processed properly. Anyone who, in good faith, reports acts violating this Code shall be treated fairly and with respect; no retaliation against such person shall be tolerated unless his/her reporting act is illegal. Names of whistleblowers shall be kept confidential to the extent possible. (Code of Conduct II. 7)

• Attitude toward Antisocial Forces and Organizations

  The Tsurumi Group shall have no relationships with antisocial forces and organizations that pose a threat to the order and safety of civil society. (Code of Conduct III. 3)

• Export/Import Transactions

  The Tsurumi Group shall carry out sound and fair import and export of products and technologies etc., in compliance with all applicable laws and regulations of the relevant countries and regions. As a member of society who longs for world peace, we shall observe all applicable laws/regulations and rules of respective relevant countries and regions regarding the export of weapons and related technologies. We shall conduct appropriate export control to ensure that our products and technologies will not be misappropriated as tools that could threaten peace and security. (Code of Conduct IV. 5)

• Prohibition of Insider Trading

  All executives and employees of the Tsurumi Group shall not engage in any stock-related transactions based on non-public information obtained from the Tsurumi Group or other companies through execution of their work duties or business transactions. (Code of Conduct V. 2)