We, the Nitori Group, are engaged in corporate activities aimed at achieving our mission of providing the foundation of prosperous home living to the global community.
This mission can only be realized by the sound implementation of daily corporate activities.
We believe that it is essential to eradicate corrupt practices such as "bribery" and "improper, unfair, or nontransparent business activities" in order to conduct sound corporate activities.
We have established this Policy as a guideline for fulfilling our social responsibilities by thoroughly ensuring that the entire Group does not engage in or be complicit in corruption.
- The Nitori Group will not recognize in any event any profits which may not be obtained without the use of bribery and other dishonest means (hereinafter referred to as "corruption").
In addition, we pledge to act fairly and faithfully as professionals in all transactions and negotiations in the execution of our business, and establishing and operating an effective system to eradicate corruption.
- In order to realize the preceding paragraph 1, we will comply with the laws and regulations concerning the control of corruption (including not only the Japanese Penal Code and the Unfair Competition Prevention Act, but also foreign laws and regulations that may apply to the Nitori Group, such as the Anti-Bribery Act of the United Kingdom and the U.S. Foreign Corrupt Practices Act (FCPA) ), and implement or promote various measures to develop and operate anti-corruption systems and ensure their effectiveness.
2. Scope of the Policy
This Policy applies to all officers and employees of the Nitori Group (hereinafter referred to as "Officers and Employees etc.") .
3. Prohibition of corruption
- It is prohibited to directly or indirectly grant, promise or offer, or approve any and all monetary benefits or facilities to public officials or persons equivalent thereto (hereinafter referred to as "Public Officials etc.") for the purpose of acquiring or maintaining business or business convenience for the Nitori Group, whether domestic or overseas.
This includes providing Public Officials etc. with illegal remuneration and rewards, such as facilitation payments (small payments that are not based on the laws and regulations required to smoothly implement administrative procedures).
- It is prohibited to give, offer, or promise a monetary benefit to other business operators or individuals other than Public Officials etc., regardless of domestic or overseas, for the purpose of requesting them to perform illegal duties.
It is also prohibited to accept requests for monetary benefits from other businesses for the same purpose.
- It is prohibited to give or receive entertainment, gifts, remuneration, aid money, etc. that are in violation of applicable laws and regulations of each country or a deal/a transaction, or that are beyond the scope of social common sense, to or from all regional companies including Nitori Group companies.
4. Hiring business partners
The Nitori Group does not appoint any individual or organization (including consultants, advisors, agents, brokers, distributors, customs brokers, etc., hereinafter referred to as "Business Partners") that provides information, services, conducts transactions, or provides business assistance to us if the Business Partners engage in or are likely to engage in corruption.
5. Creation and retention of records
To ensure compliance with this Policy, officers and employees must record all costs and expenditures, including payments to Business Partners, in a complete, accurate, and timely manner in accounting books, records and other reports.
6. Establishing systems to prevent corruption
- The Chief Compliance Officer (CCO) is solely responsible for the Company's efforts to prevent corruption under this policy. The department in charge of compliance assists the CCO as the secretariat.
- The Nitori Group's business group, category, department, management group, category, department, and each compliance manager of Group companies in Japan and overseas shall be responsible for the development and operation of related regulations and internal procedures (hereinafter referred to as the "Related Regulations, etc.") in each organization and for the development of systems necessary to implement training and development activities and other policies for officers and employees, etc. Any compliance issues, including corruption, require immediate report to the CCO and the secretariat.
7. Responsibilities of Officers and Employees
- Officers and Employees etc. must understand and comply with this Policy and Related Regulations, etc.
- Officers and Employees etc. shall avoid acts that violate or may violate this Policy. If there is reasonable suspicion that a violation of this Policy has occurred or may occur in the future, officers and employees must immediately report the matter appropriately in accordance with the prescribed procedures.
8. Violation of this Policy
- Officers and Employees etc. who violate this Policy and related rules shall be subject to disciplinary action in accordance with related rules.
- We will also take certain measures against our Business Partners if they violate this Policy.
Established May 20, 2021