Anti-Bribery Policy

1. Purpose

The Nissin Foods Group hereby adopts this Anti-Bribery Policy for the purpose of complying with laws and regulations for prohibition of any bribery applicable in the countries and regions in which the Group operates its business and the rules, guidelines, etc. of the group companies and practicing business conduct in adherence to social ethics.

2. The Requirements

The Nissin Foods Group shall require all its officers, advisors, employees, contracted workers, temporary workers, dispatched workers and any other persons in any form of employment with the Nissin Foods Group as well as consultants, agents and other third parties (hereinafter, “Outsourcing Contractors, etc.”) to whom the Nissin Foods Group entrusts certain business as follows:

(1) Prohibition of bribery
Never offer, promise and provide to any person or request, promise and receive any bribe, directly or indirectly.
(2) Prohibition of entertainment or gifts to public officials
Never offer entertainment or gifts to public officials; provided, however, in exceptional cases, for any offer of engaging in entertainment or gifts within the common sense socially accepted, appropriate approval procedures shall be executed, followed by suitable posterior verification.
(3) Building sound business relationships
Conduct business only with lawful and transparent counterparties and endeavor to incorporate an anti-bribery article into contracts with the counterparties.
(4) Regular risk assessment, review and improvement
Assess bribery risk regularly, review the rules, guidelines, etc. and internal controls concerning the anti- bribery and make revisions and improvement as necessary.
(5) Thoroughness in accounting record management
Prepare accurate books for all transactions of the company in reasonable detail and retain records.
(6) Reporting
Report promptly to take action appropriately in a timely manner, if any suspected violation of laws and regulations concerning the anti- bribery and rules, guidelines, etc. of the group companies is found.