The Nissin Foods Group shall comply with relevant anti-corruption* laws and regulations, and shall conduct business activities with fairness and integrity in relation to its customers, business partners and all other stakeholders.

This policy, which sets forth basic attitudes and actions for preventing corruption, applies to all the Nissin Foods Group's 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, “Outsourced Contractors, etc.”) to whom the Nissin Foods Group entrusts certain business.

• *For the purposes of this policy, a corrupt act is the misuse of official authority, whether directly or through a third party, to gain an unlawful benefit, including:

• -Bribery i.e. offering, promising, providing, requesting or receiving any bribe, and entertainment or gifts to public officials;
• -Unfair competition, including collusion and cozy relationships, and the giving of benefits or the giving of favors to a third party in the form of goods or information;
• -Money laundering i.e. concealing the origin of illicit gains and disguising them as legitimate income;
• -Conflicts of interest i.e. acts conducted by a person on a private basis and in an inappropriate manner to gain own benefits in conflict with the interest of the entity to which the person belongs;
• -Receiving or giving of excessive entertainment or gifts, and fraud such as rebates and kickbacks.

We shall fully understand and comply with anti-corruption laws and regulations applicable in the countries and regions in which we conduct business.

We shall establish a compliance division and a compliance committee, and shall establish the structure necessary for the Nissin Foods Group's compliance with anti-corruption laws and regulations, guidelines, etc. We shall establish a structure through which officers, employees and others can promptly seek advice on and report violations and potential violations of all the anti-corruption laws and guidelines, etc. applicable in each country and region, and the guidelines stipulated in this policy.

We shall raise awareness of this policy, the Group's anti-bribery policy and other relevant internal rules by making them available for officers and employees at all times in internal materials, on the Intranet, etc. We shall also provide regular in-house anti-corruption education and training to officers, employees and Outsourcing Contractors, etc. in an effort to prevent corrupt acts and raise risk awareness.

We shall prepare accurate accounting records in reasonable detail and keep records of all transactions to fulfil our responsibility for explaining compliance with each country's anti-corruption laws, regulations, guidelines and this policy.

We shall monitor anti-corruption initiatives and compliance according to the risks within the countries and regions in which we execute business and business activities and we shall verify the effectiveness of such initiatives. We shall also review this policy and procedures for complying herewith as necessary, and promote its continuous improvement.

We shall establish a whistleblowing hotline through which officers, employees and others can promptly seek advice on and report violations and potential violations of all the anti-corruption laws and guidelines, etc. applicable in each country and region, and this policy. We shall deal with whistleblowing reports fairly and properly, ensuring that whistleblowers and those cooperating with investigations are not treated disadvantageously or subjected to retaliation.

We will enforce strict and prompt disciplinary action in accordance with the internal regulations and work rules of each Group company against officers, employees and others who violate laws and regulations, or the guidelines stipulated in this policy. Additionally, we will also take firm action in cases of corruption involving Outsourced Contractors etc.