ANTI-BRIBERY POLICY

The Axvircle Anti-Bribery Policy (hereinafter referred to as ‘this Policy’) sets out specific measures based on the principles outlined in the ‘Axvircle Code of Conduct’.

Officers and employees (including temporary staff) of Axvircle Co., Ltd. (hereinafter referred to as ‘Axvircle’) shall aim to establish fair business practices by preventing bribery and corruption based on this Policy and complying with anti-corruption laws and regulations in each country.

Officers and employees of Axvircle shall not engage in bribery in any country or region where the company conducts business. Should an officer or employee of Axvircle receive a request or offer of bribery from a public official, they shall refuse it.
*Except in unavoidable circumstances to avert danger to the life, body, or liberty of the officer or employee.
‘Bribery’ refers to the direct or indirect provision or acceptance of money, gifts, hospitality, or other benefits to a public official, with the purpose of inducing or refraining from inducing that official to perform or refraining from performing an act related to their official duties, for the purpose of Axvircle or the counterparty obtaining or maintaining a transaction.

Axvircle shall properly record and retain, in accordance with internal regulations, all monetary and other benefit exchanges occurring during business operations.

Axvircle shall implement appropriate training to prevent bribery by officers and employees.

Axvircle shall detect and rectify violations early through the operation of its internal audit system and whistleblowing system. Furthermore, where there is a risk of violation, it shall conduct appropriate investigations to prevent such occurrences.

Axvircle shall impose penalties in accordance with internal regulations upon directors and employees who violate this policy and shall notify relevant authorities as necessary.

Axvircle shall also seek the understanding and cooperation of its business partners (suppliers) regarding this policy.

June 2024
Axvircle Co., Ltd.
President and Representative Director
Yuto Kamijo