Kurita Group Anti-Bribery Policy

01. Objectives of this Policy

This Policy sets forth basic matters related to anti-bribery and matters to be observed by officers and employees (hereinafter, the “Officers and Employees”) of Kurita Water Industries Ltd.
(hereinafter, “KWI”) and its consolidated subsidiaries (hereinafter, “Group companies”; KWI and Group companies are hereinafter collectively referred to as the “Kurita Group”). The purpose of this Policy is to prevent acts of bribery, etc., acts that may constitute bribery, etc., or acts that may be misunderstood as bribery, etc. and to promote fair business activities at the Kurita Group.

02. Policy

A. General Provisions
  1. In accordance with this Policy, the Kurita Group prohibits acts of bribery, etc. of public officials, etc. (to be defined in B.1) that are performed by the Officers and Employees of the Group and establishes anti-bribery regulations, etc. in order to define structures and rules that are needed to prevent bribery, etc.
  2. In accordance with this Policy, the anti-bribery regulations, etc. prescribed in (1) above shall be in compliance with laws, rules and regulations and rules that will apply to the Kurita Group in each country or region where the Group operates its business (hereinafter collectively, “Local laws and Regulations”) and standards permitted by Local laws and Regulations.
  3. The Officers and Employees shall observe this Policy and anti-bribery regulations, etc. and prevent bribery, etc.
  4. When any Officer or Employee of a Group company has paid a bribe, etc. to a public official, etc., has received a demand to pay a bribe, etc. or has conducted an act that may be suspected of being bribery, etc., the relevant Group company shall immediately report to KWI.
B. Definitions
1. Public officials, etc.

Public officials, etc. are persons falling under any of the following items, whether they are in or outside the country.

  • Officers and employees of the country's national or local government (hereinafter collectively, "Governments, etc.");

  • Officers and employees of government agencies over which the relevant government, etc. has authority or control; Note that government agencies include national (public) enterprises owned by national governments (public entities) and national (public) enterprises operated by national governments (public entities) as well as private enterprises over which Governments, etc. are deemed to have practical authority or control;

  • Officers and employees of political parties;

  • Officers and employees of international organizations;

  • Officers and employees of an organization which carries out administrative affairs based on delegation from a government, etc. or an international organization;

  • A Diet member, local assemblyman or chief of a local government (including candidates for public office); or

  • Officers and employees prescribed in (i) to (vi) above include spouses, children, parents, siblings or any other family members of said officers and employees.

2. Corrupt intent

Corrupt intent means the intention to wrongfully influence public officials, etc. in the performance of their duties for the purpose of obtaining transactions in business activities or favorable treatment. In concrete terms, corrupt intent includes the following cases: Specific examples are shown in the Group Anti-Bribery Guidelines.

3. Bribery, etc.

Bribery, etc. shall include an act of giving bribe to public officials, etc., an act of offering to pay a bribe to public officials, etc. or an act of promising to pay a bribe to public officials, etc., with corrupt intent through the following acts or by pretending to perform the following acts, and also include the case where an Officer or Employee personally bears the relevant expenses. Specific examples are shown in the Group Anti-Bribery Guidelines.

4. Agents, etc.

Agents, etc. mean legal entities or individuals who provide the Kurita Group with information or services, business transaction, representation or meditation by acting as agent, mediator, deputy, consultant or distributor, regardless of their names.

C. Prohibition of bribery, etc.
  1. Officers and Employees may not pay bribes, etc. to public officials, etc., directly or through a third party (including agents, etc.), and may not conduct acts that may be misunderstood as bribery, etc.
  2. In the event that a public official, etc. demands a bribe, etc., the relevant Officer or Employee shall firmly refuse such demand.
  3. If an Officer or Employee faces a demand for a bribe, etc. from a public official, etc. and is compelled to pay the bribe, etc. because, without the Officer's or Employee's immediate compliance with the demand, the life, body, etc. of the Officer or Employee or of a third party will be in imminent danger, then the Officer or Employee may comply with the demand in order to avoid the danger; the Officer or the Employee may comply with such demand in order to avert present danger; provided, however, that the Officer or the Employee shall record the situation and report to the Chief Compliance Officer prescribed in the anti-bribery regulations, etc. immediately after the dangerous situation is over in accordance with the provisions of the Group Anti-Bribery Guidelines.
D. Advance approval procedures

An Officer or an Employee may provide benefits, etc. to, bear expenses for, or provide donations, etc. to a public official, etc. only when the Officer or the Employee obtains advance approval in writing from the Chief Compliance Officer as prescribed in the anti-bribery regulations, etc. The methods for recording and reporting are established in the Group Anti-Bribery Guidelines.

E. Relationships with private companiesE.

This Policy applies mutatis mutandis to relationships with officers and employees of private companies in the same manner as it does to relationships with public officials, etc. in countries and regions where the Provision, etc. of benefits, etc. to, Bearing of expenses for, or Provision of donations, etc. to officers and employees of private companies are regulated under Local laws and Regulations. In this case, “public officials, etc.” in this Policy shall be read as “officers and employees of private companies.”

F. Provision of entertainment, gifts, etc. from business partners

Officers and Employees may not receive the provision of entertainment, gifts, benefits or other economic benefits from suppliers, subcontractors or other business partners beyond the scope permitted by Local laws and Regulations.

G. Education and training

The Kurita Group shall develop and implement systems for providing compliance education and training concerning the prevention of bribery, etc. of public officials, etc. on a regular basis.

H. Periodic review and continuous improvement of systems for preventing bribery, etc.

For the prevention of bribery, etc. of public officials, etc., the Kurita Group shall conduct periodic audits of the systems for preventing bribery, etc. through means such as audits by the internal audit department and self-inspection, and implement continuous improvement measures as necessary.

03. Confirmation of status and review of the policy

  • KWI shall continuously monitor anti-bribery initiatives at the Kurita Group based on this Policy.

  • KWI shall review this Policy every year and as needed based on the status of anti-bribery initiatives at the Kurita Group in accordance with latest regulatory developments relating to this Policy.

04. Changes, etc. to this policy

  • The department responsible for enforcing this Policy shall be the Integrity and BCMPromotion Department of the Corporate Planning Division of KWI.

  • The amendment and abolition of this Policy shall be as established in the ManagementRegulations for Policies and Regulations of KWI.

A. Supplemental provision
  1. This Policy shall be established and take effect on March 1, 2017.
  2. This Policy shall be revised and take effect on April 1, 2026.