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Compliance Policy Regarding Anti-Bribery

This Compliance Policy represents and affirms the Yamato Group’s policy under which we seek to prevent bribery and corruption, which hinders fair and free competition.  We understand that each company of the Yamato Group and all of its officers and employees are obliged to comply with this Policy and any violation hereof may lead to a disciplinary action, and hereby make the following declaration.

1. We understand that any bribery or corruption, which hinders fair and free competition, must not be allowed to occur, and strictly comply with the provisions of:

  • the Penal Code, the Unfair Competition Prevention Act, the National Public Service Ethics Act, and the National Public Service Ethics Code of Japan;
  • Foreign Corrupt Practices Act of the U.S.,;
  • the Bribery Act of the U.K.,;
  • the Penal Code, Malaysian Anti-Corruption Commission Act 2009, Customs Act 1967 and any amendments thereto, and other Malaysian legislation or law prohibiting bribery and corruption; and
  • other anti-bribery laws of any country  (“Anti-Bribery Laws”).

2. We do not commit any acts that may be suspected as bribery or corruption. Particularly, we do not:

  • corruptly solicit, receive, agree to receive from any person; or
  • corruptly give, promise or offer to any person,

whether the above mentioned person is an officer of a public body or otherwise, any gratification as an inducement to or as a reward for any person doing or forbearing to do anything in respect of any matter or transaction, actual or proposed or likely to take place.

3. We maintain appropriate relationships with any person whom we may contact in the course of the performance of our duties.

4. We do not commit any act of providing meals, entertainment, gifts or rewards, unless such acts are acceptable in light of Anti-Bribery Laws and: 

  • no unfair intention is found from an objective perspective; or
  • such acts are truly unavoidable in order to protect the life, body, property or freedom of an individual or his/her family members.

5. Even in the event that provision or receipt of meals, entertainment, gifts or rewards to or from others is permitted, we do so only after undergoing prescribed approval procedures and only to the extent necessary in order to perform our duties.

6. We require any supplier, contractor, dealer, agent, consultant or other third party which is engaged in the Yamato Group’s businesses and services to strictly comply with Anti-Bribery Laws.

 

 

Compliance Policy Regarding Competition Laws

This Compliance Policy represents and affirms the Yamato Group’s policy under which we comply with any competition law of any country, which is one of the fundamental rules of the market.  We understand that each company of the Yamato Group and all of its officers and employees are obliged to comply with this Policy and any violation hereof may lead to a disciplinary action, and hereby make the following declaration.

  1. As a participant of the market, we strictly comply with any competition law, which is one of the fundamental rules. We do not commit any act whatsoever that hinders fair and free competition, such as being part of a cartel or carrying out collusive biddings, transactions by unfair means, or business combinations capable of limiting competition.
  2.  
  3. We do not make any arrangement with any of our competitors on a matter that should be independently determined by each company, including prices, quantities, customers, sales channels, suppliers, facilities, or technologies. 
  4.  
  5. In no event do we exchange with any of our competitors any information about a matter that should be independently determined by each company, including prices, quantities, customers, sales channels, suppliers, facilities, or technologies (“Competitive Information”).
  6.  
  7. If we are requested by any of our competitors to provide any Competitive Information, we will expressly reject such request and promptly report such event to designated personnel in charge of compliance and risk management and seek directions therefrom.
  8.  
  9. If we unintentionally obtain any Competitive Information from any of our competitors, we will promptly report such event to designated personnel in charge of compliance and risk management and seek directions therefrom.
  10.  
  11. To ensure that no Competitive Information is exchanged with our competitors, we carefully examine and determine the necessity of participating in meetings, parties, golf competitions, trips or any other gathering where any of our competitors may be present.
  12.  
  13. We do not attempt to communicate with any of our competitors in ways that raise suspicions that we have exchanged any Competitive Information with such competitors, including through conversation, phone, fax, email, social media or otherwise.
 

Compliance Policy Regarding the Prevention of Discrimination and Harassment

This Compliance Policy represents and affirms the Yamato Group’s policy as a member of society under which human rights of all persons must be respected, and any discrimination or harassment, which infringes upon human rights, must not be tolerated.  We understand that each company of the Yamato Group and all of its officers and employees are obliged to comply with this Policy and any violation hereof may lead to a disciplinary action, and hereby make the following declaration.

 

  1. We strictly comply with any law and regulation in Malaysia relating to the prevention of discrimination and harassment and ensure our respect for human rights. We do not commit by ourselves or allow anyone to commit any acts of discrimination or harassment, which infringes upon human rights.
  2.  
  3. We do not commit or allow anyone to commit any discrimination based on race, belief, gender, religion, nationality, age, origin, etc. 
  4.  
     (i)We do not commit or allow anyone to commit sexual harassment, including any sexual language or behavior that deteriorates an employee’s working condition, or any   disadvantageous treatment of an employee by reason of his/her reaction to such language or behavior.

     (ii)We do not commit or allow anyone to commit power harassment, including any act taking advantage of official authority or seniority that causes an employee to suffer   mental or physical pain or deteriorates the workplace environment.

     (iii)We do not commit or allow anyone to commit any other forms of harassment, including harassment in relation to pregnancy, giving of birth or childcare leave, and will   not allow the creation of any hostile work environment.

     
  5. We never retaliate or take any adverse personnel action whatsoever against an employee for reporting any discrimination or harassment or for cooperating in an investigation regarding discrimination or harassment.
  6.  
  7. If we receive a report of discrimination or harassment, we will conduct investigations and appropriately address such issue.