Kurita Group Anti-Bribery Policy

General provisions

  1. (1)In accordance with this Policy, the Kurita Group prohibits acts of bribery, etc. of public officials, etc. that are performed by the Officers and Employees of the Group and establishes anti-bribery regulations, etc. in order to define structures and rules that are needed to prevent bribery, etc.
  2. (2)In accordance with this Policy, the anti-bribery regulations, etc. prescribed in (1) above shall be in compliance with laws, rules and regulations and rules that will apply to the Kurita Group in each country or region where the Group operates its business and standards permitted by Local laws and Regulations.
  3. (3)The Officers and Employees shall observe this Policy and anti-bribery regulations, etc. and prevent bribery, etc.
  4. (4)When any officer or employee of a Group company has paid a bribe, etc. to a public official, etc., has received a demand to pay a bribe, etc. or has conducted an act that may be suspected of being bribery, etc., the relevant Group company shall immediately report to KWI.


  1. (1)Public officials, etc.
    Public officials, etc. are persons falling under any of the following items, whether they are in or outside the country.
    • [1]Officers and employees of the country's national or local government (hereinafter collectively, "Governments, etc.");
    • [2]Officers and employees of government agencies over which the relevant government, etc. has authority or control;
      Note that government agencies include national (public) enterprises owned by national governments (public entities) and national (public) enterprises operated by national governments (public entities) as well as private enterprises over which Governments, etc. are deemed to have practical authority or control;
    • [3]Officers and employees of political parties;
    • [4]Officers and employees of international organizations;
    • [5]Officers and employees of an organization which carries out administrative affairs based on delegation from a government, etc. or an international organization;
    • [6]A Diet member, local assemblyman or chief of a local government (including candidates for public office); or
    • [7]Officers and employees prescribed in (i) to (vi) above include spouses, children, parents, siblings or any other family members of said officers and employees.
  2. (2)Corrupt intent
    Corrupt intent means the intention to wrongfully influence public officials, etc. in the performance of their duties for the purpose of obtaining transactions in business activities or favorable treatment. In concrete terms, corrupt intent includes the following cases: Specific examples are shown in the Group Anti-Bribery Guidelines.
  3. (3)Bribery, etc.
    Bribery, etc. shall include an act of giving bribe to public officials, etc., an act of offering to pay a bribe to public officials, etc. or an act of promising to pay a bribe to public officials, etc., with corrupt intent through the following acts or by pretending to perform the following acts, and also include the case where an Officer or Employee personally bears the relevant expenses. Specific examples are shown in the Group Anti-Bribery Guidelines.
  4. (4)Agents, etc.
    Agents, etc. mean legal entities or individuals who provide the Kurita Group with information or services, business transaction, representation or meditation by acting as agent, mediator, deputy, consultant or distributor, regardless of their names.

Prohibition of bribery, etc.

  1. (1)Officers and Employees may not pay bribes, etc. to public officials, etc., directly or through a third party (including agents, etc.), and may not conduct acts that may be misunderstood as bribery, etc.
  2. (2)In the event that a public official, etc. demands a bribe, etc., the relevant Officer or Employee shall firmly refuse such demand.
  3. (3)If an Officer or Employee faces a demand for a bribe, etc. from a public official, etc. and is compelled to pay the bribe, etc. because, without the Officer's or Employee's immediate compliance with the demand, the life, body, etc. of the Officer or Employee or of a third party will be in imminent danger, then the Officer or Employee may comply with the demand in order to avoid the danger; the Officer or the Employee may comply with such demand in order to avert present danger; provided, however, that the Officer or the Employee shall record the situation and report to the Chief Compliance Officer prescribed in the anti-bribery regulations, etc. immediately after the dangerous situation is over in accordance with the provisions of the Group Anti-Bribery Guidelines.

Advance approval procedures

An Officer or an Employee may provide benefits, etc. to, bear expenses for, or provide donations, etc. to a public official, etc. only when the Officer or the Employee obtains advance approval in writing from the Chief Compliance Officer as prescribed in the anti-bribery regulations, etc. The methods for recording and reporting are established in the Group Anti-Bribery Guidelines.

Relationships with private companies

This Policy applies mutatis mutandis to relationships with officers and employees of private companies in the same manner as it does to relationships with public officials, etc. in countries and regions where the Provision, etc. of benefits, etc. to, Bearing of expenses for, or Provision of donations, etc. to officers and employees of private companies are regulated under Local laws and Regulations. In this case, "public officials, etc." in this Policy shall be read as "officers and employees of private companies."

Provision of entertainment, gifts, etc. from business partners

Officers and Employees may not receive the provision of entertainment, gifts, benefits or other economic benefits from suppliers, subcontractors or other business partners beyond the scope permitted by Local laws and Regulations.