The SG Holdings Group prohibits acts leading to corruption and is endeavoring to prevent corrupt behavior. The Code of Ethics and Conduct specifies "Distinction between Private and Public Matters," "Propriety of Business Entertainment Expenses" and "Dealings with Government Officials and Politicians," and stipulates matters such as "We will ensure that all gifts, dinners and other business entertainments are within socially acceptable bounds and such entertainments are not used for improper purposes." Furthermore, we have established the Anti-Bribery Policy specifically indicating the approach based on the Group Charter of Corporate Conduct and the Code of Ethics and Conduct. By implementing these, we comply with the laws and regulations related to bribery prevention in each country, and aim to establish fair business practices.

Furthermore, the Code of Ethics and Conduct and the Anti-Bribery Policy are always displayed on the portal site for employees to ensure employees check risks pertaining to corruption and reflect the Code and Policy in individual behavior, and employees declare that they will act in accordance with the Code of Ethics and Conduct at the start of the fiscal year.

In addition, education is implemented through measures such as Group employees periodically reading the Code of Ethics and Conduct together.

Systems Related to the Prevention of Corruption

If it is necessary to revise the Anti-Bribery Policy and the Code of Ethics and Conduct, the revisions are submitted to the Board of Directors to be resolved in order to ensure appropriate supervision.

Initiatives Related to the Prevention of Corruption

Internal Contact Points

The SG Holdings Group has established the "Compliance Hotline" to receive inquiries and reports. The Compliance Hotline has been established not only for Japan, but also for overseas, to cover reports of violations and potential violations of the Code of Ethics and Conduct and the Anti-Bribery Policy. The company acts in accordance with internal rules, and ensures the anonymity of people who file reports and other people cooperating in inquiries to provide consideration to ensure employees, etc. are not treated unfairly.

Due Diligence on M&A, etc.

The Group has added check items on bribery and prevention of corruption in legal due diligence for new deals, and performs checks on these.

Matters Related to Anti-corruption

Item Boundary Unit FY2018 FY2019 FY2020 FY2021 FY2022
Total amount of political contributions SG Holdings Group Milllion Yen 0 0 0 0 0
Donations to industry associations Milllion Yen 0 0 0 0 0
Contribution to lobbying organization Milllion Yen 0 0 0 0 0
Number of serious penalties related to corruption Cases 0 0 0 0 0
Amount of fines related to anti-corruption Milllion Yen 0 0 0 0 0