Article 1 (Purpose)
The purpose of this Basic Policy is to promote efforts against bribery and corruption (hereinafter referred to as “Bribery, Etc.”) throughout the LY Corporation Group in the spirit of fair play, and to secure the trust of stakeholders and society in general by adopting a strict policy that does not tolerate any violations on Bribery, Etc., in accordance with the LY Corporation Group Code of Conduct.
Article 2 (Scope of application)
This Basic Policy shall apply to the LY Corporation Group and all its officers and employees (hereinafter referred to as the "Officers and Employees”), regardless of the country or region in which they operate.
Article 3 (Compliance with laws and regulations)
Officers and Employees shall comply with all laws and regulations related to the prohibition of Bribery, Etc., applicable in each country or region, and internal rules including this Basic Policy, and internal regulations (hereinafter collectively referred to as the "Related Rules, Etc.").
Article 4 (Prohibition of giving bribery)
- Except as permitted by the Related Rules, Etc., Officers and Employees shall not directly or indirectly provide money, goods, or other benefits, or make offers or promises thereof, to public servants etc., as well as private sector customers and business partners, (hereinafter referred to as the "Business Partners, Etc.") with corrupt intents, both inside and outside of Japan.
- Officers and Employees shall not direct bribery through third parties such as agents, consultants, distributors, subcontractors, etc., nor tolerate or condone such third parties giving bribery.
- Officers and Employees shall not provide their money, goods, or other benefits, or make offers or promises thereof, to public servants, etc., and Business Partners, Etc., for the purpose of circumventing the provisions set forth in this Basic Policy.
Article 5 (Prohibition of facilitation payment)
Officers and Employees shall not make facilitation payments (small payments to public servants, etc., for the purpose of facilitating procedures related to non-discretionary and routine administrative services).
Article 6 (Prohibition of accepting bribery)
Officers and Employees shall not directly or indirectly receive, demand, or promise to receive corrupt or unjustified benefits, with respect to their duties, both inside and outside of Japan.
Article 7 (Lawful entertainment, gifts, etc.)
- The LY Corporation Group shall properly manage entertainment, gifts, travel expenses, donations, support, and sponsorship for public servants, etc., and Business Partners, Etc., in accordance with the Related Rules, Etc.
- The LY Corporation Group shall pay special attention to the provision of entertainment or gifts to public servants, etc., political donations, and political funds, such as by establishing separate internal rules.
Article 8 (Establishment and operation of whistleblowing desk)
- In order to ensure a structure for complying with this Basic Policy, the LY Corporation Group shall establish whistleblowing desks to which Officers and Employees can report general compliance issues, including prevention of Bribery, Etc.
- In the event that any violation or potential violation of the Related Rules, Etc. is discovered, the LY Corporation Group shall conduct a rigorous internal investigation and fully cooperate with any investigation by the relevant authorities, etc.
- Officers and Employees who violate the Related Rules, Etc., may be subject to personal liability and shall be subject to strict disciplinary actions in accordance with the internal regulations of the company to which they belong or their employment/delegation contract.
- The LY Corporation Group shall not tolerate any retaliation or disadvantageous treatment of whistleblowers or those who cooperate in the investigations on the reported matter.
Article 9 (Employment)
When offering employment or internship opportunities, the LY Corporation Group shall hire persons based on their performance and ability, without giving preferential treatment to public servants, etc. or those recommended by public servants, etc.
Article 10 (Investment or acquisition)
When making investments or acquisitions, the LY Corporation Group shall conduct appropriate due diligence in line with the characteristics of the relevant country and industry, etc. If the LY Corporation Group discovers violations or potential violations of this Basic Policy after the completion of an investment or acquisition, it shall immediately conduct investigations.
Article 11 (Training)
Considering the risk of corruption in the various markets in which the LY Corporation Group operates, the duties of Officers and Employees, and the frequency of possible contact with public servants, etc., Business Partners, Etc., the LY Corporation Group shall consider the risks of Bribery, Etc. within the LY Corporation Group and provide training programs on the prevention of Bribery, Etc. as necessary.
Article 12 (Thorough record keeping and storage)
Officers and Employees shall prepare, record, and retain accounting books, etc. that accurately and fairly reflect, in reasonable detail, all transactions and dispositions of assets, under an appropriate internal control system.
Article 13 (Monitoring)
The LY Corporation Group shall appropriately operate the systems of risk level-based self-inspections and internal audits on the status of compliance with this Basic Policy and the internal rules established based on this Basic Policy.
Article 14 (Revisions/abolition and clerical works)
- The revisions and abolition of this Basic Policy shall be resolved and implemented by the Board of Directors of LY Corporation.
- The clerical works related to the revision and abolition of this Basic Policy shall be conducted by the division in charge of compliance of LY Corporation.
Enacted and enforced on October 1, 2021
Revised on October 1, 2023
- This is an English translation of the Japanese policy. This translation is prepared and provided for the purpose of the reader's convenience. All readers are recommended to refer to the original version in Japanese for complete information.