This Compliance Policy sets out the Yamato Group’s policy under which we prevent bribery, which hinders fair and free competition. We understand that each company of the Yamato Group and all of its officers and employees are obliged to comply with this Policy and any violation hereof may lead to a disciplinary action, and hereby make the following declarations. This Policy applies to the officers (herein after refers to directors, supervisors, and senior executives such as general managers and vice general managers etc.) and the employees (herein after refers to formal employees, dispatched employees and advisors etc.) of the Yamato Group. This Policy also applies to the third party that conduct external activities representing the Yamato Group (including without limitation such professional advisors or agencies as attorneys and accountants etc.). No officers or employees of the Yamato Group shall conduct any item which is prohibited or restricted by this Policy.

1. We understand that any bribery, which hinders fair and free competition, shall not be allowed to occur. All officers and employees of the Yamato Group are prohibited from soliciting, accepting or offering any bribe in conducting the Yamato Group’s business or affairs. In conducting all business or affairs of the Yamato Group, they shall strictly comply with all local laws and regulations and also those in other jurisdictions when conducting business there or where applicable, including without limitation the provisions of the Penal Code, the Unfair Competition Prevention Act, the National Public Service Ethics Act, the National Public Service Ethics Code of Japan, the Foreign Corrupt Practices Act of the U.S., the Bribery Act of the U.K., the Prevention of Bribery Ordinance of Hong Kong, and the Anti-Unfair Competition Law, the Criminal Law and its amendments of P.R.C. as well as other anti-bribery laws of any country (“Anti-Bribery Laws”), and shall not:
   1. solicit or accept any advantage from others as a reward for or inducement to doing any act or showing favor in relation to the Yamato Group’s business or affairs, or offer any advantage to an agent of another as a reward for or inducement to doing any act or showing favor in relation to his principal’s business or affairs;
   2. offer any advantage directly or indirectly to any public servant (including Government / public body employee) as a reward for or inducement to his performing any act in his official capacity or his showing any favor or providing any assistance in business dealing with the Government / a public body; or
   3. offer any advantage to any staff of a Government department or public body while they are having business dealing with the latter.
      *Notice 1: Utmost caution is required while dealing with any staff of a Government department or public body, as a few national laws specifically prohibit conducts offering gift or money to such staff. Some of which even exercise extraterritorial jurisdictions over such conducts.
      *Notice 2: The term “advantage” includes money, gift, commission, loan, fee, reward, office, employment, contract, service, travel, donation and favor.
2. We do not commit any acts that may be suspected as bribery. Officers and employees are prohibited from offering advantages to any director, staff member or agent of another company or organization, for the purpose of influencing such person in any dealing, or any public official, whether directly or indirectly through a third party, when conducting the Yamato Group’s business. Further, officers and employees are prohibited from receiving gifts, hospitality or expenses whenever such arrangements could improperly affect, or might be perceived to improperly affect, the outcome of a procurement or other business transaction and are not reasonable and bona fide expenditures.
3. We maintain appropriate relationships with any person whom we may contact in the course of the performance of our duties.
4. In certain circumstances and cultures, the nature (e.g. advertising or promotional gift, customary gift given during festive occasions) and the value of the gift or souvenir may be such that refusal could be seen as unsociable or impolite. In these cases, the officer or employee may, subject to a maximum limit of HKD500 or USD80 in value, accept such gift or souvenir, provided that receipt of the gift or souvenir shall be reported by such officer or employee to his/her supervisor within 7 days.
5. Even in the event that provision or receipt of meals, entertainment, gifts or rewards to or from others is permitted, we do so only after undergoing prescribed approval procedures and only to the extent necessary in order to perform our duties and such acts shall be subject to Anti-Bribery Laws.
6. We require any supplier, contractor, dealer, agent, consultant or other third party which is engaged in the Yamato Group’s businesses and services to strictly comply with Anti-Bribery Laws. No officers or employees of the Yamato Group shall instruct, instigate or assist any (i) distributer, trading firm, agent, advisory body, intermediary or mediate labor that provides the Yamato Group with information or transactions regardless of their designation; (ii) retail trader, supplier and counterparty of a joint venture; and (iii) other counterparties that may be involved in the Yamato Group’s transaction with public servant etc. (herein after referred to as “Counterparty etc.”) to conduct any bribery that is prohibited by the Anti-Bribery Laws, this Policy and/or the Guidelines. Besides, no officers or employees shall pay any Counterparty etc. any money by any means if he or she has knowledge that such Counterparty etc. is conducting bribery prohibited by the Anti-Bribery Laws, this Policy and/or the Guidelines.