Skylark Group Anti-Bribery and Anti-Corruption Policy
１．Compliance with Laws and Regulations, Prohibition of Bribery, and Thorough Prevention of Corruption.
All officers and employees shall comply with this policy and other related internal regulations and report any non-compliance or potential non-compliance cases through the department in charge of compliance or the internal reporting desk in accordance with internal regulations. The department in charge of compliance shall maintain and operate an organizational structure to prevent bribery and corruption by raising such reports to the Risk and Compliance Committee for consideration.
２．Establishment and Operation of Anti-Bribery and Anti-Corruption Systems.
All officers and employees shall continue to receive education and training on a regular basis to further enhance their ethical awareness towards the prevention of bribery and corruption, and to ensure the proper operation of the anti-bribery and anti-corruption systems.
３．Education and Training
All officers and employees shall continue to receive education and training on a regular basis to further enhance their ethical awareness and to ensure the proper operation of the anti-bribery systems.
４．Audit and Reviewing Systems
All officers and employees will confirm whether the anti-bribery and anti-corruption systems are functioning effectively through regular audits, and based on the results of such audits, continuously review the effectiveness of our anti-bribery and anti-corruption systems including this policy and make improvements as needed.
５．Recording and Storing of Transaction Details
All officers and employees will, under an appropriate internal control system, accurately record approval documents, accounting books and other related documents on expenditures based on factual data, and properly store all related forms and documents, in order to support our compliance with the anti-bribery regulations of each country as well as this policy.
６．Disciplinary Action
Any officer or employee who breaches this policy or related regulations, shall face disciplinary action, and shall be punished appropriately and promptly in accordance with our Employment Regulations.
Scope of Application
All employees of Skylark Group, including officers, full-time employees, and part-time employees.
In addition, the Skylark Group has established procurement guidelines for anti-bribery and fair trade, and promotes thorough compliance and engagement with our suppliers.
* For more details on our policies, please see the page below.
https://corp.skylark.co.jp/en/sustainability/governance/compliance/
Prohibited Acts
- Bribery
Skylark Group shall comply with the anti-bribery laws and regulations of all countries and regions, and shall not, directly or indirectly, offer, promise, or give bribes, or demand, promise, or receive bribes or any other acts of bribery with any person. Furthermore, with regard to entertaining and giving gifts to customers and business partners, we have established internal regulations and appropriate approval processes, and strive for their proper management and operation.
- Facilitation Payments
Facilitation payments are small payments of money or similar benefits paid to public officials, etc., for the purpose of facilitating administrative procedures (such as permits, licenses, customs clearance, and visa issuance). Skylark Group strictly prohibits facilitation payments. We will not make or offer such payments, even if they are customary in a particular country or region, or are not explicitly prohibited by local law.
- Anti-competitive Practices
Skylark Group will not engage in any anti-competitive practices, including cartels and bid-rigging.
- Inappropriate Conflicts of Interest
Skylark Group prohibits inappropriate conflicts of interest that have not gone through prescribed internal procedures. The following are examples of conflicts of interest, but are not limited to these:
- Doing business with a company managed by an officer or employee of Skylark Group, or their close relatives such as family members or friends.
- Employing close relatives, such as family members or friends, of officers or employees of the Skylark Group or its business partners.
- Insider Trading
In the course of our business, Skylark Group may become aware of material, non-public, confidential information related to our company, our customers, or our business partners. We will not use or share this information for the purpose of securities trading or for any purpose other than the business of the company.
- Illegal Political Donations
When making political donations, we comply with all relevant laws and regulations, refrain from actions that could be misconstrued as political collusion, and strive to build sound and transparent relationships.
- Money Laundering
We prohibit money laundering intended to obscure the origin of illegally obtained proceeds through remittances or other means.
Risk Assessment
We conduct annual risk assessments related to bribery and corruption for all Group companies, including overseas subsidiaries. Based on the results of these assessments, we strive to implement appropriate risk management.
July 24, 2025
Approved by Group Sustainability Committee