Anticorruption Policy / Tax Compliance
Anticorruption Policy
To achieve the honest management pursued in its corporate philosophy, The Fujibo Group works against corruption of all kinds. Corruption signifies the abuse of authority to gain unfair benefits of all kinds, including coercion, bribery, conflicts of interest, misappropriation of rebates, and kickbacks. We require all officers, employees, and business partners of the Fujibo Group to observe the following.
Fujibo Group Anticorruption Policy
1. Compliance with laws and regulations
To prevent corruption, comply with the Unfair Competition Prevention Act and other anticorruption laws and regulations applicable in each country and region of the business operation and with the internal rules. For foreign laws and regulations, also be careful about their extraterritorial application.
2. Prohibition of bribery
It is prohibited to provide, offer, or promise bribery to public officials or equivalent individuals, either directly or indirectly. The same applies to small payments to public officials or the equivalent for the purpose of facilitating procedures (so-called facilitation payments). To maintain fair and sound relationships with business partners, it is also prohibited to provide or receive unfair money, gifts, entertainment, or other financial benefits beyond the extent considered reasonable as a social custom.
3. Appropriate approval procedures and post factum confirmation procedures
Payments, entertainment expenses, and donations to public officials or the equivalent should be made through the proper approval process. Compliance with this policy should be monitored through audits by internal audits for appropriate follow-up inspections.
4. Establishment of a system
For the prevention and early detection of corruption, a corporate ethics hotline should be established as a whistleblowing system to receive inquiries and reports from officers and employees concerning any act that violates or may violate this policy. The inquiring or reporting individual should not be treated disadvantageously.
5. Anticorruption training
Implement training for officers and employees of the Group for disseminating this policy and deepening their understanding of the prohibition of bribery. At the same time, measures against the unfair requirement for bribery on business sites should be shared to prevent the occurrence of corruption.
6. Corruption risk assessment and control procedures
For transactions conducted abroad or via an agent or other third parties or before starting a new transaction, perform risk assessment from the viewpoint of anticorruption, establish and operate proper control procedures based on the assessment results, and manage the transaction relationships.
7. Monitoring and continuous improvement
Regularly monitor the status of compliance with laws and regulations concerning corruption and with this policy and continuously improve measures for anticorruption under the supervision of the Board of Directors.
8. Penalties
If corruption-related dishonesty is uncovered or suspected, conduct a careful investigation. If the dishonesty is found to be true, identify the cause, take corrective action for recurrence prevention, and take stringent punitive action against the officers and employees involved in the corruption in accordance with the internal rules of the relevant group company.
This policy is approved by the Board of Directors of Fujibo Holdings, Inc.
September 30, 2025
Fujibo Holdings, Inc.
Masahide Inoue, Representative Director and President
Tax Compliance
1. Basic position
The Fujibo Group’s basic policy is to comply with the tax-related laws and regulations as well as the various rules of each country where it conducts business activities, while implementing tax measures in accordance with the transfer pricing guidelines and other rules established by the OECD (Organisation for Economic Co-operation and Development). We strive to properly report and pay taxes throughout the Group.
2. Tax governance
In the Fujibo Group Charter of Conduct, the Group states that it will comply with social rules, laws, and regulations both in Japan and abroad, as part of its efforts to conduct fair and sound corporate activities and to conform to the international community. It is critical to maintain and improve tax governance in order to increase corporate value. We collaborate with Group companies and divisions to share information about tax issues and report on tax enforcement conditions. Through these and other measures, we strive to develop our governance system.
3. Transactions between related companies
The Group strives to ensure that transactions with overseas related parties are conducted properly based on the arm’s length principle in accordance with OECD transfer pricing guidelines and various countries’ transfer pricing taxation principles. With an understanding of the intent of generally accepted rules and guidance related to international taxation, such as the Action Plan on Base Erosion and Profit Shifting (BEPS), the Group pays taxes in a proper and timely manner in accordance with each country’s tax laws and regulations, treaties and other rules in line with its business performance. The Group will not engage in any improper tax avoidance activity.
4. Relationships with tax authorities
The Group will respond to tax authorities with integrity and will maintain constructive and satisfactory relationships with them. The Group will conduct prior consultations as needed and will strive to conduct proper tax reporting, while working to reduce tax risk.
5. Ensure transparency
In accordance with the provisions of the Financial Instruments and Exchange Act, the Group discloses the amount of tax due, the reconciliation of the effective statutory tax rate, and other matters in its annual securities report.