Establishment of Kewpie Group Anti-Bribery Basic Policy

We, the Kewpie Group, place great importance on the words of our founder, Toichiro Nakashima, that “It is the way of the world that a person of good faith, who respects morality, will gain recognition in the long run”, and act in accordance with the criteria that “What is the truth, what is the right thing to do” regardless of immediate gain or loss it may cause. In addition, as our Group business overseas accelerates, we regard it as extremely important to establish a compliance framework on a global basis.

Furthermore, as regulations against bribery are being strengthened worldwide, the Kewpie Group has established “the Kewpie Group Anti-Bribery Basic Policy”, in preparation for constructing a framework for preventing bribery of civil servants in accordance with rules and regulations such as the Unfair Competition Prevention Act (Japan), Foreign Corrupt Practices Act (USA), and the UK Bribery Act.

We declare that we will promote anti-bribery activities thoroughly by establishment and internal/external announcement of the Kewpie Group Anti-Bribery Basic Policy in December 2015, as an important guideline for our executives and employees to follow, which brings more concrete form to our Corporate Motto, Corporate Principles and Group Policies.

Even if it would lead to an immediate gain, we will not engage in bribery, and will always select a course of action consistent with the Kewpie Group Anti-Bribery Basic Policy which clearly reflects the spirit and intent of our Corporate Motto, Corporate Principles and Group Policies.

Osamu Chonan,
Representative President and CEO
Kewpie Corporation

Kewpie Group Anti-Bribery Basic Policy

Prohibition of Bribery

We, the Kewpie Group (hereinafter referred to as “We”) prohibit any Kewpie Group *1 executives or employees *2 from taking any action involving bribery *3 that violates the laws and regulations of any country, of civil servants *4 or interested party, whether in Japan or other countries, either directly or indirectly.

Establishing a System to Prevent Bribery

Along with establishing the Kewpie Group Anti-Bribery Basic Policy, we will strengthen our internal rules, starting from subsidiaries with high necessity, to build a system to prevent bribery, and then continuing onto other subsidiaries in stages. We will make further improvements to our auditing systems by creating a whistle-blowing system, implementing internal training and educational programs, and conducting continuous monitoring and internal auditing activities. In addition, we will evaluate the effectiveness of the bribery prevention system and conduct regular reviews with the involvement of management members when required.

Retention of Payment Records

We will record accounting books correctly based on actual facts and retain records of payments properly under the appropriate internal control system.

Punishment

Should it be made clear that an executive or an employee commits bribery, the executive or employee committing the bribery will be punished in accordance with company regulations (Rules of Employment, etc.).

Agents

We will make sure agents*5 of the company know the Kewpie Group Anti-Bribery Basic Policy and demand them to comply with it. In addition, we will immediately cancel any business transaction with an agent who breaches this policy or has serious concern of breaching this policy.

*1Kewpie Group: Kewpie Corporation and domestic and foreign subsidiaries. (This Kewpie Group Anti-Bribery Basic Policy is shared with AOHATA Corporation, listed subsidiaries of Kewpie Corporation, and they are requested to respond similarly to bribery as Kewpie Corporation.)

*2Executive and employee: All corporate officers and employees (including dispatched employees, part time workers, and other temporary workers)

*3Bribery: The provision of benefits or assets, such as items of value, entertainment with meals and beverages, opportunities to elevate personal prestige and status, and observation tours in order to gain unfair benefits and advantages with regard to transactions and other areas, including making promises, offers and approvals of such.

*4Civil Servant: Persons engaged in official duties for the government or local authorities in Japan or other countries, including the countries where we conduct business; persons engaged in administrative work for an organization affiliated with a government; persons engaged in administrative work for a public corporation, in particular those who have been granted interest; persons engaged in official duties for an international organization; and persons granted authority by a government, etc.

*5Agents: A third party with whom the Kewpie Group has entered into a contractual relationship to conduct activities, either domestically or overseas, and who conducts activities as a dealer (agent), consultant, or acts on behalf or in the name of the Kewpie Group.

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