Anti-Corruption

Ebara Corporation and its domestic and overseas group companies (hereinafter referred to as "the Group") strive to prevent corruption and take voluntary and preventive measures to prevent corruption, with the aim of promoting the sound development of business activities.

All directors, executive officers and employees of the Group will be aware of and strive to promote anti-corruption in their work, comply with relevant laws and regulations, and act in accordance with the company rules.

The Group will establish and properly operate an anti-corruption program that consists not only of anti-corruption rules, but also of a reporting system and in-house education. If any violation is found in the conduct of directors, executive officers, or employees of our group, we will promptly address and correct the violation, and if necessary, we will revise the content of the anti-corruption program to prevent recurrence.
This anti-corruption program is made known to all employees.

The EBARA Group is implementing an anti-corruption program with the objectives of "promoting fair and free competition," "cutting off relationships with anti-social forces," and "prohibiting bribery." This program applies to all group companies and includes the following measures:

1. Anti-corruption declaration by the top management of each company to prohibit corrupt practices by employees and the company
2. Basic policies on anti-corruption resolved by the board of directors of each company
3. Establishment of internal regulations prohibiting corrupt practices
4. Establishment of an internal reporting system that allows employees to anonymously report serious problems
5. Make all 1 to 4 known to employees

Disciplinary measures have also been established in the event of a violation of the regulations. The "Anti-Bribery Rules" enacted by each Group company include restrictions on bribery, as well as on entertainment, gifts, travel, contributions, donations, facilitation payments, and other expenses and benefits, as well as on transactions through third parties.

The operation status of the anti-corruption program and the status of EBARA are regularly reported to the Sustainability Committee, which consists of all executive officers. The directors are also present at the board meetings, and matters related to the Sustainability Committee are reported to the board.

Shugo Hosoda
President and Representative Executive Officer
EBARA Corporation
March 27, 2025

In accordance with the "Ebara Group CSR Policy," the Ebara Group has conducted business activities based on the execution of business with high ethical standards and building relationships of trust with all our valued customers.
As part of this, the Group's "Anti-Corruption Program," which was established in 2012, is being rolled out both domestically and overseas. Here, we once again declare the EBARA Group's basic stance on preventing corruption, including the prohibition of bribery, the promotion of fair and free competition, and the severing of ties with anti-social forces, and declare that we will strictly adhere to this.

1. The directors and employees of the EBARA Group will comply with the anti-corruption program, including relevant laws and company rules, and will conduct business activities with fairness, sincerity and transparency.
2. If any director or employee of the EBARA Group violates relevant laws and company rules, the violator will be subject to strict disciplinary action in accordance with company rules. Furthermore, we will take strict action against business partners whose anti-corruption efforts are deemed insufficient, including suspending transactions with us.
3. The top management of the EBARA Group will take the lead in putting the anti-corruption program into practice, proactively disseminate messages both inside and outside the company, and demonstrate strong leadership in thoroughly publicizing the anti-corruption program. Furthermore, if any corrupt practices occur within the company, top management will take the initiative in resolving the problem, identifying the cause, and working to prevent recurrence.
4. The EBARA Group recognizes that the trust and confidence it gains from stakeholders, including society, customers, and business partners, through the performance of fair, honest, and transparent business activities, is an invaluable asset.
5. The EBARA Group will thoroughly prevent corruption through regular in-house training, revision of regulations, and reviews of compliance, based on its corruption prevention program.

Since fiscal 2013, the Group has been rolling out and implementing anti-corruption programs at its domestic and overseas group companies. Every year, we review our global Anti-Corruption Program with reference to the Corruption Perceptions Index published by Transparency International, to identify high-risk areas we conduct business in. At the same time, we will monitor the latest information on anti-corruption legislation in each country and update our regulations in a timely manner.

We also provide education to employees in relatively high-risk areas, such as sales departments.

Our Group has established multiple reporting channels so that employees can feel comfortable speaking up about any questions or concerns they may have about bribery or corrupt practices. Furthermore, Ebara Corporation and some of its domestic group companies have placed Compliance liaisons in the workplace to create an environment where employees can freely seek advice. (Related information: Compliance page)

In addition, we are strengthening our efforts to prevent bribery through third parties. Previously, we only screened high-risk cases, but we have expanded the scope of contract risk screening through a review of our regulations.

In fiscal 2022, we did not incur any fines or discipline employees in connection with bribery or other corrupt practices. The Company does not make political contributions. Additionally, there have been no corruption-related fines, penalties or settlement costs.

Our Group's "CSR Procurement Guidelines" contain information on the matters for which we would like our suppliers to cooperate. Section "9. Anti-Corruption" clearly states that "extortion and bribery are prohibited." In fiscal 2022, we conducted a CSR Procurement Questionnaire to check the level of awareness of these guidelines among our suppliers and the status of their CSR efforts. For suppliers who need improvement, we will work together with them to make continuous improvements through direct dialogue and visits.

Related information: Supply Chain Management