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The Anti-Bribery & Corruption Act at the SRD Group

Chairperson of Compliance &
Risk Management Committee
Hiromi Tazawa,
President
SRD
14/03/2019

1. Introduction

The SRD Group herein declares that the Group member neither executes any bribery act, exchanges money, provides services and/or gifts, entertains any person who is government employees, corresponding to such positions but not limited to any suppliers and/or clients in both domestic and overseas by fraudulent means which correspond to bribery, nor provides such personnel with any benefits without any legitimate motive (collectively referred to as the “Bribery & Corruption Act” hereafter).

Even when any executive and staff of the SRD Group were to receive “Bribery & Corruption Act”, they would decisively have to refuse the Act, and have to immediately notify the fact to the police and/or prosecution of each relevant country.

2. Organization System of the “Anti-Bribery & Corruption Act”

(2-1) Insertion of the “Anti-Bribery & Corruption Act” Section into Any Contract

It is an orthodox way within the SRD Group to insert the “Anti-Bribery & Corruption Act” Section into any contract to be duly signed together with suppliers and/or clients in domestic and overseas, whenever needed.

(2-2) Training of Education Programs about the “Anti-Bribery & Corruption Act”

The SRD Group makes it a regular rule to perform trainings of education programs about the “Anti-Bribery & Corruption Act” for any executive of the Group, which is being planned and carried out by the Compliance Department within the Group, in order to observe those regulations that are already prevailed in each respective country.

(2-3) Continuous Compliance Supervisions of the Laws & Guidelines related to the “Anti-Bribery & Corruption Act”

The SRD Group makes it a regular rule to continuously supervise compliance conditions of the laws & guidelines related to the “Anti-Bribery & Corruption Act” being conducted by any executive and staff of the SRD Group, by means of hearing their comments and/or delivering questionnaires to them, on a regular basis.

(2-4) Implementation of the Internal Reporting Desk

The SRD Group has already implemented the Internal Reporting Desk within its organization structure. And, whenever the Internal Reporting Desk where to find out violations of the “Anti-Bribery & Corruption Act”, they would have to take immediate corrective action.

(2-5) Internal Audit System

The SRD Group makes it a regular rule to periodically survey a compliance condition of the “Anti-Bribery & Corruption Act”, and the SRD Group is obliged to make its sincere efforts to appropriately sustain and improve this internal audit system.

END