The THK Group has established the “THK Group Anti-Bribery Policy” regarding the prevention of bribery throughout the THK Group.
Previously, the THK Group had worked to prevent bribery in accordance with the “THK Group Action Charter”. However, as laws surrounding bribery and disclosures are becoming stricter around the world, we have deemed it necessary to further clarify the THK Group’s stance on bribery prevention as we promote various activities, and have therefore established this policy.
Established: December 2021
Based on the fundamental principle of prioritizing legal compliance over short-term gains, the THK Group adheres to the following provisions as it promotes efforts to prevent bribery.
In order to promote the anti-bribery efforts established in this Policy, the THK Group evaluates the risk of bribery within the Group and establishes rules related to the prevention of bribery at each Group company in accordance with the characteristics and risks present in each country and region, and the THK Group regularly monitors, inspects, and evaluates whether those rules are being correctly applied. Furthermore, the THK Group reevaluates the anti-bribery management structure in accordance with the results of the evaluation.
The THK Group conducts training for executives and employees as well as utilizing other means to disseminate information and deepen understanding of bribery prevention.
The THK Group exercises due diligence before engaging in business with the Business Partners of each Group company and strives to introduce anti-bribery provisions into agreements with such Business Partners.
The THK Group accurately records all transactions in its accounting books and appropriately stores all related materials.
The THK Group maintains a helpline and reporting line in order to detect bribery and other such acts at an early stage. Furthermore, all THK Group executives and employees are required to quickly file a report if they have discovered bribery or another such act.
In the event that a major compliance violation related to bribery is made known, the THK Group promptly and appropriately conducts an investigation and takes other necessary actions. Furthermore, the THK Group earnestly handles any requests to cooperate with investigations conducted by law enforcement in each country.
The THK Group deals severely with any executive or employee that has violated anti-bribery laws or this Policy in accordance with the internal regulations of each Group company.
In addition to disseminating the contents of anti-bribery laws and this Policy among your executives, employees, and suppliers, the THK Group requests that its business partners do not engage
in any acts that are or may be in violation of anti-bribery laws or this Policy in the course of conducting business and transactions with the THK Group.
If you become aware of an act that occurred during a business dealing or transaction with the THK Group and either is or may be in violation of such regulations, we ask that you promptly notify the relevant THK Group and provide your full cooperation with any investigation performed by the THK Group or the relevant legal authorities of each country.