Skylark Group Anti-Bribery Policy
１．Compliance with Laws and Regulations and Prohibition of Bribery
All officers and employees shall comply with the anti-bribery laws and regulations of all countries and regions, and shall not offer, promise or give bribes, or demand, promise or accept bribes, or engage in any other act of bribery (including small facilitation payments), whether directly or through intermediaries.
２．Establishment and Operation of Anti-Bribery Management Systems
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 by raising such reports to the Risk and Compliance Committee for consideration.
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 systems are functioning effectively through regular audits, and based on the results of such audits, continuously review the effectiveness of our anti-bribery 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.
November 1, 2021
Approved by Group Sustainability Committee