THK Group Anti-Bribery 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.

1. Prohibition of Bribery

1. The THK Group does not directly or indirectly commit bribery, nor make offers or promises thereof to anyone.
2. The THK Group does not make facilitation payments (small bribes for the purpose of expediting administrative procedures) to public officials or those in equivalent positions (hereinafter referred to as “Public Officials”).
3. The THK Group pays heed to the particular laws of each country and region, including those that forbid bribery toward private enterprises in addition to Public Officials, and adheres to applicable anti-bribery laws in the execution of its business.
4. In recognition that any bribery committed by a representative or business partner (hereinafter referred to as “Business Partners”) may be considered bribery on the part of the THK Group, the THK Group does not instruct its Business Partners to commit bribery. Furthermore, the THK Group does not tolerate any actual bribery on the part of any Business Partners, or indications thereof, of which the THK Group is aware.

2. Establishment, Operation, and Internal Auditing of an Anti-Bribery Management Structure

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.

3. Thorough Execution of Bribery Prevention and Dissemination of Information

The THK Group conducts training for executives and employees as well as utilizing other means to disseminate information and deepen understanding of bribery prevention.

4. Exercise of Due Diligence and Introduction of Anti-Bribery Provisions

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.

5. Thorough Management of Records

The THK Group accurately records all transactions in its accounting books and appropriately stores all related materials.

6. Maintenance of a Helpline and the Obligation to Report

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.

7. Emergency Response

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.

8. Penalties

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.