IDEC Group Anti-Corruption Policy
1. Basic Approach
The IDEC Group has established “The IDEC Way” as a new philosophy with the aim of becoming a truly global company. One of the Core Values that we must share, as stated in “The IDEC Way,” is “Integrity,” which means that we should face everything with sincerity and act with honesty and fairness to continue being a trusted entity. To this end, the IDEC Group established the “IDEC Group Code of Conduct,” which explicitly prohibits corrupt acts under “Business Ethics and Fair Business Practices.” To define these basic guidelines more specifically, we hereby establish the “IDEC Group Anti-Corruption Policy.”
■Purpose
This policy aims to establish standards for preventing corruption within the IDEC Group and to declare both internally and externally that we do not tolerate any corrupt acts. Recognizing that corrupt acts such as bribery, corruption, and fraud in business activities affect the fair and sustainable development of society, and that global companies are expected to address corruption prevention, the Group will work together to prevent corruption.
■Scope of Application
This policy applies to all individuals working within the IDEC Group and its subsidiaries and affiliates, including directors, officers, employees, and contract workers, temporary staff.
■Definitions
(1) Corrupt acts:
Acts such as bribery, conflicts of interest, fraud, money laundering, extortion, and embezzlement, carried out for the purpose of obtaining illicit benefits in any form, including but not limited to cash, donations, gifts, entertainment, business opportunities, employment, and services.
(2) Bribery:
Providing, offering or promising something of value for the purpose of obtaining or maintaining business or securing an undue advantage, regardless of whether the recipient is a public official or a private individual.
(3) Anything of value:
Includes any benefit, whether tangible or intangible, including but not limited to cash, gift cards and other cash equivalents, gifts, meals, travel and entertainment, business or employment opportunities, and any promises or guarantees.
(4) Facilitation payment:
A small monetary payment made to a public official to make routine, non-discretionary administrative procedures that the official should normally perform happen faster or more reliably. Published administrative fees paid directly to the government or a state-owned entity do not fall under this category.
(5) Public official:
A person who is paid from government funds or who performs a public function. This includes persons working for local governments, state/provincial governments, national governments, or international public organizations, as well as employees of public (government-owned or operated) schools, hospitals, and state-owned enterprises. Employees of such organizations are regarded as public officials regardless of title or position.
(6) Conflict of interest:
Any activity or situation in which an employee’s personal interests actually conflict, or appear to conflict, with the Company’s interests, resulting in the employee’s business judgment, decisions, or actions being improperly influenced, or appearing to be improperly influenced. A conflict of interest does not arise solely from existence or prioritization of personal interests, but only where such interests actually influence, or appear to influence, the employee’s business judgment, decisions, or actions.
(7) Disadvantageous treatment:
Dismissal, disciplinary action, threats, or other unfavorable treatment that occurs as a result of concerns raised by an individual.
2. Compliance with Applicable Laws and Regulations
The IDEC Group is committed to acting with integrity in all circumstances and complying with anti-corruption and anti-bribery laws applicable in the countries and regions where we operate, including France’s Sapin II Law, the United States Foreign Corrupt Practices Act (FCPA), and the United Kingdom Bribery Act.
If local laws or regulations are stricter than the provisions of this policy, we must comply with those local requirements. The IDEC Group does not prevent each Group location from having its own policies and guidelines to supplement this policy in accordance with local laws.
3. Prohibition on Involvement in Corrupt Practices
The IDEC Group maintains sound relationships with business partners, local communities, public agencies, governments, and does not engage in or tolerate any form of corrupt practices whatsoever, whether active or passive, or direct or indirect.
(1) Bribery
The IDEC Group has a zero-tolerance approach to bribery. The IDEC Group neither offers nor accepts gifts, entertainment, compensation, benefits, or anything else of value that could be considered to improperly influence business decisions or create a sense of obligation.
(2) Facilitation Payments
The IDEC Group prohibits all improper payments, including facilitation payments.
(3) Political Contributions
The IDEC Group will not provide company funds or assets to political parties, politicians, or their candidates without appropriate prior internal approval in accordance with internal rules.
(4) Sponsorships and Donations
The IDEC Group supports local community groups and charitable organizations. Sponsorships and donations will be conducted appropriately after confirming they are legal and ethical.
(5) Improper Hiring Practices
The IDEC Group treats all applicants fairly and consistently based on unified selection criteria, including applicants referred by third parties. The IDEC Group does not offer any employment, including internships or contract positions, for the purpose of obtaining or retaining business or gaining a business advantage.
(6) Conflicts of Interest
The IDEC Group has a zero-tolerate conflicts of interest. Employees related parties must comply with the following in order to ensure that their personal activities or interests do not, and do not appear to, compromise the interest that affects or may affect themselves:
Not to engage in business while intentionally concealing a conflict of interest that affects or may affect themselves;
To avoid transactions, involvements, or relationships that may conflict with one’s duties to the IDEC Group;
Not to participate in any decision-making where they may conflict with their duties to the IDEC Group;
Not to be directly involved in employing relatives or close friends
4. Response to Extortion and Threats
The IDEC Group recognizes that extortion may be involved when bribery, corruption, or facilitation payments are demanded, and that resistance may not be realistic, or that resisting could put the personal health, safety, and security of employees and their families at risk. If employees face such a crisis, they follow appropriate procedures and take action in accordance with instructions from the Risk Management Committee.
5. Whistleblowing (Internal Reporting)
To strengthen the compliance and risk management system, the IDEC Group has established internal and external consultation and reporting channels (IDEC Hotline). Employees may consult with or report to the IDEC Hotline if they have concerns about corrupt acts or face a crisis. The IDEC Group protects whistleblowers who report in good faith from any disadvantageous treatment.
The IDEC Group will not disclose the personal information or consultation details of the person seeking advice or reporting, except to those who need to know. No disadvantageous treatment will be taken against those who consult, report, or cooperate with investigations.
6. Relationships with Business Partners
The IDEC Group requires its business partners, including agents, consultants, contractors, and suppliers, to comply with this policy.
The IDEC Group selects its business partners through fair and transparent procedures and conducts business only with companies that comply with this policy and applicable laws and regulations.
7. Corruption Risk Assessment and Due Diligence
The IDEC Group regularly conducts risk assessments to identify, evaluate, analyze, and mitigate corruption risks within the Group. Based on a risk-based approach, we prioritize anti-corruption efforts in high-risk business activities.
For high-risk activities, we investigate the compliance status and assess business-partner risk levels based on factors such as industry, country/region, transaction amount, and others. For business partners assessed as high risk, we may include contract clauses requiring legal compliance and audit rights, or consider terminating the transaction. The IDEC Group also monitor risk conditions regularly and appropriately assesses corruption risks across the IDEC Group.
8. Accurate Accounting and Record-Keeping
The IDEC Group complies with applicable accounting laws and standards, carries out proper accounting under an appropriate internal control system, and maintains transparent accounting records and reporting. Records will be retained to confirm and objectively demonstrate that no improper acts have occurred.
9. Training and Communication
The IDEC Group provides employees with regular training on this policy and on preventing corruption, including bribery.
10. Disciplinary Actions
The IDEC Group takes a strict stance against corruption. If an employee or other individual subject to this policy violates this policy or applicable laws and regulations related to anti-corruption, we will respond in accordance with internal rules.
11. Promotion and Governance Structure
Within the Sustainability Committee chaired by the President, the Risk Management Committee (a specialized subcommittee) promotes anti-corruption initiatives and regularly monitors policy reviews, operational status, and effectiveness.
Initiatives are reported twice a year through the Sustainability Committee, and the Board of Directors provides oversight.