The azbil Group Basic Policy on Anti-corruption Practices

Through “human-centered automation”, the azbil Group brings “safety, comfort, and fulfillment” to people and helps to preserve the global environment. Based on the “azbil Group philosophy”, the “Guiding Principles for azbil Group Business”, and the “azbil Group Code of Conduct”, we recognize that the prevention of corruption is one of our most important management issues to realize a sustainable society. We maintain high ethical standards, understand, and comply with relevant laws and regulations and strive to prevent all forms of corruption in Japan and overseas. We will build and maintain long-term, fair and sound relationships of trust with customers and business partners (hereinafter “business partners, etc.”), and with all other stakeholders.

Purpose and scope
The purpose of this policy is to contribute to the achievement of a sustainable society by requiring all officers and employees of the azbil Group, regardless of country or region, to comply with the applicable laws and regulations aimed at preventing corruption and to prevent corruption in business activities.
Compliance with relevant laws and regulations
We comply with all international treaties, laws, and regulations aimed at preventing corruption that apply in the countries and regions where our Group’s operational bases are located and where we conduct business.
Prohibition of corruption
We do not directly or indirectly participate in any form of corruption—including extortion, bribery, conflicts of interest, obstruction of justice, money laundering, and insider trading—in any of the countries and regions where we operate.
- (1) Bribery
  We do not give, offer, receive, request, or promise bribes (money, gifts, entertainment, or any other type of benefit to gain an unfair advantage) to/from public officials or their equivalents, domestic or foreign (hereinafter ”public officials, etc.” ) or private business partners, etc. In addition, we do not make facilitation payments^* to public officials, etc.
  
  * This refers to the inappropriate payment of a small sum of money to expedite or facilitate the provision of ordinary administrative services.
- (2) Excessive entertainment and gifts
  Even if it does not strictly qualify as bribery, we do not give or receive entertainment or gifts that violate applicable laws and regulations in any country or region, or that exceed sound business practices and social common sense, in dealings with public officials, etc., and business partners, etc.
- (3) Giving or receiving unfair advantage
  We do not give or receive unfair advantage to or from business partners, etc.
- (4) Conflicts of interest
  We do not engage in any act that is against or may be against the interests of the azbil Group by pursuing our own interests or the interests of a third party, and we avoid situations where such conduct may be suspected.
- (5) Insider trading
  If we become aware of undisclosed material facts concerning the azbil Group or other listed companies, we do not use that information for insider trading; also, to prevent insider trading by others, we do not divulge that information.
- (6) Inappropriate political/administrative association
  We maintain sound and transparent relationships with government and administrative bodies, and do not make political or other donations in the name of the azbil Group without complying with applicable laws and regulations and the procedures of the azbil Group.
Accurate accounting records
Regarding payments and other expenditures to third parties, we keep accurate, fact-based records in ledgers, etc., properly manage any related documentation, and ensure compliance with laws and regulations related to the prevention of corruption.
Education
We properly educate all officers and employees so that they can act in accordance with this policy in all business activities of the azbil Group.
Compliance system
In order to ensure compliance with this policy, we maintain a whistleblowing system that ensures strict confidentiality and prohibits reprisal. We conduct a thorough internal investigation if any violation or possible violation of this policy is discovered.
Handling violations
If we discover that an officer or employee of the azbil Group has violated or may have violated this policy, we will promptly report it to the person in charge of compliance, such as a contact person for the azbil Group’s whistleblowing system. It is accepted that if an officer or employee of the azbil Group violates anti-corruption laws or internal regulations, including this policy, strict disciplinary action will be taken based on the internal regulations of the azbil Group company to which the officer or employee belongs.

January 1, 2023
Kiyohiro Yamamoto
President & Group CEO
Azbil Corporation