Basic Policy on Anti-Bribery for the Veltra Group

1. Purpose

The VELTRA Group is committed to maintaining the highest ethical standards and strictly adheres to all applicable anti-bribery laws and regulations in the countries and regions where it operates. These include, but are not limited to, Japan's Unfair Competition Prevention Act, the U.S. Foreign Corrupt Practices Act (US FCPA), and the UK Bribery Act 2010 (hereinafter referred to as Anti-Bribery Laws and Regulations). This Basic Policy applies to all officers and employees across the VELTRA Group.

2. Definitions

● The term “Public Officials” encompasses all government employees, political parties, and candidates for public office, along with officers and employees of state-owned or government-controlled enterprises and entities.

● “Business Partners” refers to any party with which the VELTRA Group conducts business, including agents (i.e., agents, agencies, consultants, or any other persons who, regardless of title, provide services such as information provision, transaction intermediation, representation, or brokerage on behalf of the VELTRA Group).

● “Bribery” is defined as offering, promising, giving, or authorizing the giving of anything of value to a public official or any other person to obtain or retain business or secure an improper advantage.

● “Policy” refers to the principles and rules that all officers and employees of each company within the Group must comply with regarding the prohibition of bribery, including this Basic Policy and other policies, regulations, standards, guidelines, etc., of each Group company.

3. Compliance Requirements

The VELTRA Group requires all officers and employees of each Group company to comply with the following.

1. Prohibition of Bribery

Under no circumstances should customer offer, promise, give, or authorize the giving of, or accept or solicit, any bribe to any person, whether directly or indirectly.

2. Understanding and Compliance with Anti-Bribery Laws and Policies

Thoroughly understand and strictly comply with all applicable anti-bribery laws and the company's anti-bribery policy.

3. Prohibition of gifts and hospitality to public officials

Gifts and hospitality to public officials are generally prohibited. However, exceptions may be made within the scope of generally accepted social norms, provided that appropriate approval is obtained beforehand and proper post-event follow-up is conducted.

4. Establishing Sound Business Relationships

Engage in business transactions only with legitimate and ethical business partners, and make every effort to incorporate anti-bribery provisions into all agreements with these parties.

5. Regular Risk Assessment, Review, and Improvement

Conduct periodic assessments of bribery risks and conduct a review of anti-bribery policies and controls. Make necessary updates and enhancements.

6. Strict adherence to record-keeping

To demonstrate compliance with anti-bribery laws and policies, we will maintain accurate and factual accounting records and store related documents per internal regulations.

7. Prompt Reporting

Any suspected violation of anti-bribery laws or policies by Veltra Group employees or business partners must be reported immediately to allow for timely and appropriate action.

Enacted on January 20, 2023

Veltra Corporation

Representative Director & CEO: Wataru Futagi

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