Anti-Bribery Policy / Tax Compliance
Anti-Bribery Policy
The Fujibo Group recognizes bribery as a serious risk factor that undermines corporate credibility. We focus on preventing any form of corruption, including bribery, collusion, embezzlement and breach of trust, and ensuring a sound business environment. We have established the following "Fujibo Group Anti-Bribery Policy" to ensure thorough compliance with anti-bribery laws and internal regulations applicable in the countries and regions where we conduct business, and to demonstrate ethical and honest behavior. We request all officers, employees and business partners to thoroughly abide by this policy.
Fujibo Group Anti-Bribery Policy
1. Prohibition of bribery
The Group will not give, offer or promise bribes to any person, directly or indirectly, and will neither accept bribes.
2. Appropriate approval procedures and post factum confirmation procedures
The Group will make payments to public officials following the appropriate approval procedures, and conduct appropriate post factum confirmation such as monitoring the status of compliance with this Policy through internal audits.
3. Establishment of an anti-bribery promotion system
Through training, etc., the Group will ensure full understanding and compliance with laws and regulations relating to bribery and this Policy.
4. Bribery risk assessment and control procedures
The Group will conduct risk assessment related to anti-bribery laws and regulations, and establish and operate risk-appropriate control procedures. When commencing transactions with a new business partner or at the time of an M&A, etc., the Group will carry out a preliminary assessment of the counterparty according to bribery risk.
5. Keeping of records and maintaining financial control
The Group will maintain records and financial control to ensure accountability in compliance with anti-bribery laws and regulations and this Policy. In addition, the Group will periodically review this Policy and its compliance procedures, and make the appropriate revisions and improvements as necessary.
6. Penalties
In the event that an officer or employee violates anti-bribery laws or regulations or this Policy, the Group will carry out the necessary investigation properly and promptly, and will take the appropriate punitive action against the violating party in accordance with the internal regulations of each Group company.
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.