The SG Holdings Group prohibits acts leading to corruption and is endeavoring to prevent corrupt behavior. The Group' 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, the Code of Ethics and Conduct is always displayed on the portal site for employees and also included in the "Employee Handbook" that employees can carry to ensure employees check risks pertaining to such corruption and reflect the Code in individual behavior. At the start of the fiscal year, employees sign the handbook to swear that they will act in accordance with the Code of Ethics and Conduct.

Furthermore, education on the Code of Ethics and Conduct including the policy on prevention of corruption is implemented through measures such as Group employees periodically reading it together.

Systems Related to the Prevention of Corruption

If it is necessary to revise the Code of Ethics and Conduct containing the policy on prevention of corruption, 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" and the "Ask Anything" consultation office to receive inquiries and reports. The Compliance Hotline is available not only in Japan, with English and Chinese contact points (Web) also established to cover reports of violations and potential violations of the Group Code of Ethics and Conduct including the policy on prevention of corruption. 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
Total amount of political contributions SG Holdings Group Yen 0 0 0
Number of serious penalties related to corruption Cases 0 0 0
Amount of fines related to anti-corruption Yen 0 0 0