To our valued business partners:
Yamaguchi Financial Group
With the aim to set forth specific measures necessary to achieve the prevention of bribery amidst the global trend of firmer enforcement and heavier penalties against providing and receiving briberies, Yamaguchi Financial Group, Inc., together with its consolidated subsidiaries and equity method affiliates, has put in place these Guidelines for Prevention of Bribery, which summarize the points we request our business partners to comply with.
We truly appreciate for your understanding of the spirit of these Guidelines and your cooperation for implementing them.
Yamaguchi Financial Group, Inc., its consolidated subsidiaries and equity method affiliates (hereinafter collectively referred to as “YMFG” or “we”) will conduct fair trade in compliance with anti-bribery laws and regulations applicable in the country and region in which it operates.
We request all business partners who are involved in our business to understand the spirit of these Guidelines and to cooperate with us to implement them.
For the avoidance of doubt, the “business partners” referred to in these Guidelines include our customers, service providers, service distributors, intermediaries, alliance partners, consultants, joint venture partners, contractors, suppliers and others who are involved in the operation of YMFG.
YMFG will not seek any profits which could be gained only through bribery or other illicit means.
We remind our valued business partners not to, in the course of the business you may engage with YMFG, in order to obtain or retain business or other improper advantage in the conduct of business in relation to YMFG (*1) whether in Japan or overseas and whether directly or indirectly, with an intention to affect the performance of official duties of a public official or a person in a similar position (hereinafter referred to as “Public Official, etc.”; * 2), offer, promise or give any entertainment, gift, benefit or other advantage (hereinafter referred to as “Benefit, etc.”; * 3), or approve these conduct, whether directly or through intermediaries, to such Public Official, etc.
(* 1) To “obtain or retain business or other improper advantage” includes, among others, the following:
(* 2) “Public Official, etc.” includes, among others, the following (regardless of in Japan or overseas):
(* 3) “Benefit, etc.” includes, among others, the following:
(*) Facilitation payment
Facilitation payments refer to the payment of small amount made to a Public Official, etc. solely for the purpose of facilitating normal administrative services. Facilitation payments may hinder the efficient operation of government agencies and subsequently may impair the economic development and the rule of law, and therefore are prohibited in many countries as a form of bribery. YMFG prohibits facilitation payments.
YMFG will not seek any profits which could be gained only through bribery or other illicit means.
We remind our valued business partners not to, in the course of the business you may engage with YMFG, in order to obtain or retain business or other improper advantage in the conduct of business in relation to YMFG whether in Japan or overseas, with an intention to cause unlawful performance of duties by a third party and either in return of such unlawful performance of duties or with a knowledge that the receipt by such third party of the Benefit, etc. constitute amounts to unlawful performance of duties, offer, promise or give any Benefit, etc., or approve these conduct, whether directly or through intermediaries, to such third party or permit them to be offered, promised or given.
Our officers and employees are subject to strict rules against bribery and favoritism which prohibit their receipt of personal benefit, commission, or loans from a customer, and accordingly will not receive any gift or entertainment in violation of laws and regulations or against social ethical standards. We appreciate for your understanding and cooperation.
Please examine in advance the appropriateness of all and any transactions which may involve provision of entertainment, gift, benefit or other advantage. In such case, we recommend you may prepare and keep the record of accounts in a timely and accurate manner.
We request our valued business partners to provide trainings, etc. to keep the spirit of these Guidelines and relevant anti-bribery laws and regulations properly appreciated among your officers and employees, customers, contractors, sub-contractors and other third parties. In case you plan to outsource a duty involving communication with a Public Official, etc. to a third party, we recommend you may conduct an assessment (due diligence) to evaluate whether such third party is appropriate for the role
In the event that, in the conduct of business in relation to YMFG, you have violated these Guidelines or anti-bribery laws and regulations, etc. of Japan or overseas, have come to be aware of a fact which may suggest such violation, or have been notified of it by a relevant authority, please notify YMFG without delay and cooperate for investigation which may be conducted by YMFG or a relevant authority.
These Guidelines may be amended or added if YMFG sees it necessary after obtaining relevant external professional advice. The latest version of these Guidelines will be made available, promptly after it comes into force, on the official website of Yamaguchi Financial Group, Inc.
Established on December 20, 2019
Revised on February 28, 2020
