Simplex Group Basic Policy on Anti-Corruption

1.Positioning of this Policy

The Simplex Group (the “Group”) conducts its business based on its management philosophy of “Innovations from Japan to the world,” positioning its 5DNA code of conduct and Simplex Philosophy as important values. We recognize that corruption, including bribery of public officials, is one of the most important issues to address in the course of our business. As such, we view this as a matter that should be addressed with resolve in the spirit of “Professionalism,” one of the 5DNA code of conduct. The Simplex Group Basic Policy on Anti-Corruption has been established to express the Group’s basic position on this issue.

2.Scope of Application

This Policy applies to all Simplex Group companies.

3.Compliance with Anti-Corruption Laws and Regulations

The Group declares that it will strictly adhere to domestic and international anti-bribery laws and regulations, and that its directors and employees will not offer, solicit, or promise bribes to any public official.

4.Methods Used by Simplex to Help Ensure Anti-Corruption

Based on a risk-based approach, the Group prepares countermeasures in each business that are appropriate to the level of involvement with public officials and the level of impact. It also raises awareness and educates its directors and employees on various anti-corruption systems. In accordance with the Whistleblower Protection Act, we have also established a whistleblower hotline staffed by third-party attorneys to receive anonymous anti-corruption reports from directors or employees. If a report is made to the aforementioned contact point or relevant authorities and the information is communicated to the Group, we will immediately contact our lawyer or other appropriate professional and take strict measures in coordination with the relevant authorities.

Simplex Holdings, Inc.
Representative Director, President and CEO
Hideki Kaneko

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