Anti-bribery Guidelines
Established March 2023
1. Purpose
ASTI's Management Principle is that "we will strive to efficiently produce the fine products desired by our society while promoting integrity in management to build trust and enhance the cultural style of those around us" and unhealthy and illegal practices such as bribery are contrary to our founding principles.
These Anti-Bribery Guidelines have also been formulated with the intention of reaffirming our Management Principle.
These Anti-Bribery Guidelines have also been formulated with the intention of reaffirming our Management Principle.
2. Basic Policy
Any and all members of ASTI and its related subsidiaries (hereinafter referred to as “ ASTI Group") shall comply with all applicable laws, regulations, and other rules (hereinafter referred to as "Anti-Bribery Laws, etc.") that are intended to prevent bribery in the countries and regions in which ASTI Group operates.
3. Specific Guidelines for Action
(1) Prohibition of Bribery
Any and all members of ASTI Group will not engage in the bribery (see Note 1) of public officials, etc., (see Note 2) or customers (private entities or individuals) of ASTI Group in the countries or regions where ASTI Group operates for the purpose of obtaining or maintaining undue profits in their business activities.
(Note 1)
To offer, provide, promise, or accept, directly or indirectly, money, gifts, entertainment, treat, services, employment, or other benefits (anything of any value, tangible or intangible) with fraudulent intent or purpose, and in return ask a third party to act illegally, unethically, or immorally (improper benefits) or inflict the same on a third party.
(Note 2)
Public officials, etc. generally refer to entities or individuals set forth in i. - iii. below. Specifically, they are subject to the provisions of the applicable Anti-Bribery Laws, etc.
i. Any individual holding a legislative, administrative, or judicial office
ii. Public enterprises and their employees
iii. Enterprises entrusted with the business of an administrative organ and its employees
(Note 1)
To offer, provide, promise, or accept, directly or indirectly, money, gifts, entertainment, treat, services, employment, or other benefits (anything of any value, tangible or intangible) with fraudulent intent or purpose, and in return ask a third party to act illegally, unethically, or immorally (improper benefits) or inflict the same on a third party.
(Note 2)
Public officials, etc. generally refer to entities or individuals set forth in i. - iii. below. Specifically, they are subject to the provisions of the applicable Anti-Bribery Laws, etc.
i. Any individual holding a legislative, administrative, or judicial office
ii. Public enterprises and their employees
iii. Enterprises entrusted with the business of an administrative organ and its employees
(2) Record Management
ASTI Group shall properly account and record all transactions, expenditures, and the disposal of assets in accordance with its internal regulations and procedures, and ensure that such records are appropriately retained.
(3) Reporting System
Each company of ASTI Group shall establish a reporting window for consultation and reporting on any act that violates or is suspected to violate applicable Anti-Bribery Laws, etc., or these Guidelines (hereinafter referred to as "Violations, etc.").
Any and all members of ASTI Group shall promptly report any Violations, etc. to their superiors, to the reporting window, or through appropriate channels when they become aware of said Violations, etc.
When ASTI Group becomes aware of Violations, etc., it shall investigate said Violations, etc. appropriately and take the necessary corrective action.
Any and all members of ASTI Group shall promptly report any Violations, etc. to their superiors, to the reporting window, or through appropriate channels when they become aware of said Violations, etc.
When ASTI Group becomes aware of Violations, etc., it shall investigate said Violations, etc. appropriately and take the necessary corrective action.
(4) Education
All members of ASTI Group shall be provided with the necessary education by each company of ASTI Group in order to comply with these guidelines.
(5) Penalties
Any member of ASTI Group who violates applicable Anti-Bribery Laws, etc., or these Guidelines shall be subject to disciplinary action in accordance with the disciplinary regulations established by each company.