Measures to Prevent Corruption

The Denka Group Ethics Policy prohibits officers and employees from engaging in bribery or other illegal activities as well as from providing or receiving entertainment or gifts of excessive value or the nature of which violates social norms, laws and regulations. In addition, the Standards of Business Conduct stipulate that the officers and employees of the Denka Group must comply with the anti-corruption laws of the countries and regions in which the Denka Group operates, including the Foreign Corrupt Practices Act in the United States, the Bribery Act 2010 in the United Kingdom, and the Unfair Competition Prevention Act in Japan, and prohibit them from engaging in any form of bribery, including bribery through a third party. Further, the Standards of Business Conduct require that officers and employees of the Denka Group limit entertainment and gifts to the extent that is legal and socially acceptable, and to select the best business partners for the company based on objective criteria rather than personal gain. Denka also alert ourselves about bribery when engaged in transaction overseas and entering a new field of business. Before entering into M&A proceedings, Denka conducts due diligence to ensure that there is no risk of corruption in the acquired company, and provides education at overseas subsidiaries. Our subsidiaries in Singapore have in place strict internal rules on providing or receiving gifts or entertainment in compliance with the laws and regulations of the country.

Response to anti-social forces, money laundering and other crimes

The Denka Group Ethics Policy strictly prohibits the provision of benefits to anti-social forces. In addition, the Standards of Business Conduct stipulate that Denka Group officers and employees must not have any relationship with anti-social forces, must respond resolutely to unreasonable demands, including legal action, and must not engage in or cooperate with criminal activities such as drug trafficking, terrorism, arms smuggling, fraud, or money laundering. Through the Denka Global Compliance Program, Denka educates officers and employees of the Denka Group at home and abroad about cutting ties with antisocial and criminal forces, including the prevention of bribery and money laundering. In addition to these measures, the Legal Department is working to stipulate anti-social force exclusion clauses and anti-corruption clauses in various contracts. In Japan, the Administrative Department is working together with outside lawyers, police authorities, and professional organizations to lead efforts to ensure that the Denka Group has no relationship with anti-social forces.