Asahi Group Anti-Bribery Principles
Asahi Group will act in an ethical and sincere manner, ensuring strict compliance with anti-bribery laws and regulations applicable in each country and region where we do business, as well as relevant internal policies.
1. Prohibition of bribery
- Asahi Group will not provide, offer, or promise to provide bribes, directly or indirectly, to any person or entity, or accept bribes from anyone.
- Asahi Group will not engage in acts of bribery, including making facilitation payments, to public officials or quasi-public officials (hereinafter referred to as “Public Officials”) to gain any unfair advantage.
- Asahi Group will seek to ensure that any external persons or companies acting on our behalf such as agents or business partners (hereinafter referred to as “Business Partners”) comply with these Principles.
2. Establishment of a management system to promote anti-bribery
- Asahi Group will establish a management system necessary to promote compliance with laws and regulations related to anti-bribery, which includes making sure that officers, employees, and Business Partners are familiar with and follow these Principles.
- Asahi Group will establish a management system that enables prompt consultation with and reporting to the compliance team as designated by each Asahi Group company in the event that an officer, employee, or Business Partner is suspected of violating the applicable anti-bribery laws and regulations or these Principles.
3. Bribery risk assessment and necessary control procedures
- Asahi Group will regularly assess the bribery risks and will put in place control procedures appropriate for the risks.
- To prevent bribery of Public Officials through Business Partners, Asahi Group will conduct due diligence of Business Partners at the start of transactions, appropriate for the level of bribery risk. When an acquisition, merger, joint venture or other similar arrangement is being considered, an assessment of the counterparty will be made in advance in accordance with the level of bribery risk.
4. Proper accounting, record-keeping, and monitoring
- To fulfill our accountability towards complying with the applicable laws and regulations related to anti-bribery or these Principles, Asahi Group will keep accurate accounting records based on the facts, and will properly maintain relevant evidence according to the internal policies of each Asahi Group company.
- Asahi Group will regularly conduct self-assessments on compliance with these Principles, and will cooperate with investigations such as those by internal auditors and regulatory authorities in each country and region. Asahi Group will conduct regular reviews of these Principles and corresponding procedures, and will make revisions and improvements as required.
5. Disciplinary measures
Asahi Group will strictly discipline officers or employees who violate the applicable anti-bribery laws and regulations or these Principles, according to the internal policies of each Asahi Group company.