KOMORI Group Basic Policy on Anti-bribery and Corruption

Enforced on December 26, 2017


Laws and regulations controlling bribery and corruption have tightened on an international scale in recent years, with exposure of such activities becoming ever more severe. Although the KOMORI Group has always endeavored to prevent violations through our corporate behavior charter which includes the statement of "fair and transparent corporate activities in accordance with laws, regulations, and social ethics," and specifically defining employee standards of conduct as "prohibiting bribes to civil servants." In light of the global development of the Group's business, tightening laws and regulations, and more severe exposure of such activities, it is necessary for the KOMORI Group as a whole to further enhance measures against the risk of bribery.


In 2011, the board of directors expressed their resolve to ensure that the KOMORI Group "takes a firm stance on preventing bribery." In view of increasing worldwide interest in preventing bribery such as the American Foreign Corrupt Practices Act, the British Bribery Act, the Chinese Commercial Bribery Regulations, and the Japanese Unfair Competition Law, we declare that the laws and regulations regarding anti-bribery measures that apply in the countries and regions where the KOMORI Group operates its businesses will be strictly adhered to, that reception of bribes is prohibited, and that accurate records of all Group transactions will be maintained. In addition to eliminating bribery from the businesses involved in the Group, we request that companies who conduct business on our behalf, whether fully or partially, and our partners in business dealings, be in compliance with anti-bribery laws and regulations in order to conduct our business with integrity.


The KOMORI Group requests the following of all Group executives, employees, agents, and business partners.

1. Prohibition of bribes

Do not give, offer, promise, or accept bribes to or from any person, whether directly or indirectly.

2. Proper authorization procedures and follow-up confirmation procedures

Payments to public officials must conform to proper authorization procedures and proper follow-up confirmation (review procedures). The same also applies to payments to executives of private enterprises.

3. Understand and abide by KOMORI Group policy on bribery regulations

Undergo training to sufficiently understand and abide by laws and regulations on bribery and the KOMORI Group code of conduct.

4. Due diligence and introduction of anti-bribery clauses by agents and business partners

Business may only be conducted with legitimate and trustworthy agents and business partners, due diligence must be conducted before executing business with such persons, and the contract concluded with such parties must contain an anti-bribery clause.

5. Periodic risk evaluation

Bribery risk evaluation must be conducted periodically for all KOMORI Group companies.

6. Records maintenance

Records must be maintained in order to show compliance with bribery-related laws and regulations and the KOMORI Group code of conduct.

7. Periodic review and improvements

The code of conduct and controls for preventing bribery and corruption must be periodically reviewed and amended/improved as necessary.

8. Prompt reporting

If any KOMORI Group executive, employee, agent, or business partner is suspected of violating the anti-bribery laws and regulations or the terms of this policy, a report must be promptly filed with the immediate supervisor or supervisor of the department in charge in order to take timely and appropriate measures.


  • "Public officials" include all public officials, members of a political party, official candidates, and state-owned businesses and businesses under the control of the government (examples include employees and executives at a state-owned bank).
  • "Agents" refer to persons who act as an intermediary in transactions or act on behalf of or as an intermediary for the KOMORI Group.
  • "Business partners" refers to those with whom the KOMORI Group conducts business.
  • "Bribes" denotes presenting something of value to a civil servant or other party with the goal of obtaining or maintaining business or obtaining unfair advantages, and a so-called facilitation payment (payment intended to facilitate government affairs) would constitute a bribe.
  • The "code of conduct" is a set of rules and concepts that must be followed by all KOMORI Group executives and employees which covers the policy, regulations, standards, and guidelines on preventing bribery and includes the KOMORI Group Basic Policy on Anti-bribery and Corruption.