NOK Group Policy on Prevention of Corruption and Bribery

Established on April 1, 2023

The NOK Group declares in NOK Charter of Corporate Behavior that it will maintain "fair, transparent, and free competition, appropriate business transactions, and sound and normal relations with political and administrative authorities,” and that corruption and bribery are prohibited.
As a signatory to the United Nations Global Compact, the NOK Group respects the Ten Principles of the United Nations Global Compact and has established the NOK Group Policy on Prevention of Corruption and Bribery to further promote measures to prevent corruption and bribery.
Under this policy, the Group has established a basic policy on preventing bribery of domestic and foreign public officials and those in a similar position (hereinafter referred to as "Public Officials") as well as private citizens and private companies. By complying with this policy, the Group will sincerely engage in the prevention of corruption through its business activities and endeavor to improve the sustainability and transparency of both society and companies.

1.Compliance with Laws and Regulations

We will observe laws and regulations prohibiting bribery (hereinafter referred to as "bribery related laws and regulations") in the performance of group duties in the countries and regions concerned.

2.Prohibition of Provision or Receipt of Illicit Profit

We will not engage in any acts (including facilitation payments) that are prohibited by bribery related laws and regulations for the purpose of obtaining illicit or unfair profits, regardless of whether domestic or foreign, directly or indirectly, public officials, private citizens, or private companies.

3.Prohibition of Bribery Through Third Parties

We will prevent bribery through third parties and will not tolerate such acts by appropriately managing business relationships with third parties, such as agents and consultants.

4.Proper Accounting and Record Management

We will keep accurate and factual accounting books and other records for all transactions related to this policy, perform appropriate accounting procedures, and properly maintain these records.

5.Education and Training

We shall provide education and training on the prevention of corruption and bribery for officers and employees to thoroughly inform them of the purpose and content of this policy.

6.Effective Operation of the Whistle-Blowing System

We will establish a contact point for consultation and reporting for when we recognize an act that violates or may violate this policy, and we will use this contact point to prevent, detect early, and correct the act in question.

7.Risk Assessment and Review

We will periodically assess risks of corruption and bribery, handle high-risk business activities in a focused manner, and review this policy and responses based on this policy as necessary.

8.Monitoring and Continuous Improvement

We will monitor the status of compliance with this policy and internal rules concerning the prevention of corruption and bribery, and make continuous improvements based on the results.