Nagata Seisakusyo Co., Ltd. and Nagata Co, Ltd. have established this policy as a guideline to ensure that the entire company is thoroughly committed to preventing corrupt practices and acts that contribute to corruption and to fulfilling its social responsibilities.

1. Basic Concept

The purpose of this policy is to require all officers, employees, etc. of Nagata Seisakusyo Co. Ltd. and Nagata Co., Ltd. to comply with the anti-corruption laws and regulations of Japan and other countries, whether in Japan or abroad, and thereby ensure the prevention of corrupt practices and acts complicit in corruption.

2. Compliance with applicable laws and regulations

Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. shall comply with the laws and regulations applicable in each country and region where we operate.

3. Prohibited acts

Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. prohibit their own directors, officers, employees, etc., whether in Japan or abroad, and whether the other party is a public official, etc., or a person in the private sector from directly or indirectly engaging in corrupt practices and acts that contribute to corruption.

4. Management of payment records

In the event that the officers and/or employees of Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. provide money or other benefits to third parties with whom they come into contact in the course of performing their duties, Nagata Seisakusyo Co., Ltd, and Nagata Co., Ltd. shall require its employees to properly keep all vouchers, accounts, amounts, etc., and to accurately and without omission record them in the accounting books, and to ensure that no off-balance-sheet transactions are made under any circumstances.

5. Education

Nagata Seisakusyo Co., Ltd. and Nagata Co, Ltd. will properly educate their directors, officers, employees, and other related personnel to ensure that this policy is properly implemented in the company’s business activities.

6. Disciplinary action against violations

Nagata Seisakusyo Co., Ltd. and Nagata Co. Ltd. shall take strict disciplinary action against any officer or employee of Nagata Seisakusyo Co., Ltd. or Nagata Co., Ltd. who violates this policy in accordance with the internal rules to which the officer or employee belongs.
Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. shall take all necessary measures to ensure that this policy is strictly enforced. Any advisors, consultants, agents, contractors, etc. appointed by Nagata Co., Ltd. and Nagata Co, Ltd. shall also be dealt with strictly in the event of any violation of this policy.

7. Compliance

The management of Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. shall be responsible for ensuring that its directors, officers and employees comply with this policy. In the event that an officer or employee of Nagata Seisakusyo Co, Ltd. or Nagata Co, Ltd. discovers any acts that violate or may violate this policy, he/she shall promptly report it to the company.

8. Scope of application

This policy applies to all officers, employees, etc. of Nagata Seisakusyo Co., Ltd. and Nagata Co, Ltd. All business partners involved in the business activities of Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. are also requested to understand and cooperate with this policy.

9. Supplementary clause

This policy supplements the provisions of the NAGATA Group Corporate Philosophy.

Corrupt practices:
Abuse of one’s own or a third party’s professional power or position, such as bribery, embezzlement, extortion of benefits, and improper bidding.

Bribery:
Offering, promising, or actually offering to provide money or other benefits or advantages for the purpose of obtaining benefits or advantages by improperly influencing the other party’s duties
The term “bribery” refers to both “bribery” in which a bribe is offered and “corruption” in which a bribe is demanded or a benefit or advantage is actually received.

Actions that are complicit in corrupt practices:
Obstruction of justice, concealment of corrupt proceeds, money laundering, and abetting, aiding, or conspiring in corrupt acts.

Employees:
Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. employees, contract workers, part-timers, and temporary workers dispatched to Nagata Seisakusyo Co., Ltd. and Nagata Co., Ltd. and other stockholder, a person who works under the direction and orders of Nagata Seisakusyo Co, Ltd. and Nagata Co., Ltd.

Civil servants:
This includes, but is not limited to, national public officials, local public officials, persons engaged in public service in international organizations, persons deemed to be engaged in public service by law or regulation, and executives and employees of companies substantially controlled by the government or local public entities.