YAMADA GLOBAL ANTI-CORRUPTION POLICY

1．Purpose

Yamada Manufacturing Co., Ltd. and its subsidiaries (collectively, “YAMADA”) remains true to its founding idea “to contribute as a business enterprise to society and increase the prosperity of our lives by producing products of superb quality at low cost,” which is now adopted as the Company Principle, and upholds “fair business activities & contribution to the community” in the Conduct Guidelines. YAMADA is resolutely opposed to all forms of corrupt practices such as bribery (“Corrupt Practices”) that have significant negative effects on all societies and economies, because they are against YAMADA’s Company Principle and Conduct Guidelines.
YAMADA establishes YAMADA Global Anti-corruption Policy (the “Policy”) to more thoroughly promote its anti-corruption efforts and contribute to the sustainable development of all countries, regions and societies in which YAMADA is involved.

2．Scope

The Policy applies to all of Yamada’s officers and employees (“Officer(s)/Employee(s)”).
In addition, we would like to ask all of our business partners to understand the Policy and cooperate with us.

3．Prohibition of Corrupt Practices

YAMADA, either directly by itself or indirectly through a third party, will never engage in any Corrupt Practices or suspected Corrupt Practices against public officials, etc. and customers, client companies or other business partners in the private sector. Under any circumstances, YAMADA will not accept and will firmly refuse profits that can only be obtained through Corrupt Practices.
In addition, YAMADA will not instruct any agent, consultant, distributor, contractor or other third party to conduct Corrupt Practices, nor will it tolerate or permit their Corrupt Practices.

4．Compliance with Laws and Regulations

In the performance of its business activities, YAMADA will comply with all anti-corruption laws and regulations applicable in each country or region.

5．Anti-corruption System

In order to strengthen Yamada’s anti-corruption efforts, each compliance officer of YAMADA will ensure and be responsible for the development of systems necessary to implement the Policy in each company, including the development and operation of relevant rules and internal procedures, and education and awareness activities for the Officers/Employees.

6．Whistleblowing and Hotline help desk

If any Officer/Employee or concerned party finds Corrupt Practices or suspected Corrupt Practices, he/she should immediately consult or report to the relevant compliance officer or hotline help desk. The Officer/Employee will not be disadvantaged on the grounds of such consultation/report.

7．Audits

YAMADA will audit the compliance with and operation of the Policy according to the appropriate method that takes account of the characteristics, risk level, etc. of each case.

8．Measures against Corrupt Practices

Upon becoming aware of Corrupt Practices or suspected Corrupt Practices by an Officer/Employee, YAMADA will promptly conduct the investigation and cooperate in the investigation conducted by the relevant authorities.
YAMADA will take disciplinary actions or other strict measures against any Officer/Employee involved in Corrupt Practices, in accordance with relevant rules, and in light of his/her personal responsibility in law.

9．Establishment, Revision and Abolition

The establishment, revision and abolition of the Policy will be subject to approval of the board of directors.

Established on April 1, 2024