Anti-Bribery policy

Toyobo Group Anti-Bribery policy

Toyobo Group, at its Charter of Corporate Behavior, declare to promote fair business practices as one of the principles and to prohibit bribery to public officials, customers and business partners, either within in the country or abroad, and to prevent receipt of unfair benefits.
In order to promote proper activities toward anti-bribery program, we hereby enact this policy and endeavor to work on those together as a group in light of the characteristic and risks lied on the countries and regions in which we do our businesses.

1.Compliance with Anti-Bribery Laws and Regulations

All directors, officers and employees of Toyobo Group shall comply any and all applicable anti-bribery laws and regulations relating to anti-bribery in the countries and regions^* when performing their duties.

2.Prohibition of Bribery

All directors, officers and employees of Toyobo Group shall not, directly or indirectly, give, offer or promise to give money and any other profit^*to Public Official, etc.^*, and any other business partners so as to gain unfair business benefits.

3.Prohibition of Acceptance of a Bribe (Prohibition of Receipt of Unfair Profits)

All directors, officers and employees of Toyobo Group shall not, directly or indirectly, demand or receive unfair profits in connection with business activity.

4.Prohibition of Bribery through an Agent and Others

All directors, officers and employees of Toyobo Group shall not direct a third party such as an agent, consultant, or distributor, etc., to bribe or shall not give them a silent approval to bribe.

5.Proper Record and Maintenance

All directors, officers and employees of Toyobo Group shall record all trades in accounting books accurately and keep all the relevant documents properly.

6.Audit

Toyobo Group will conduct the audit based on a risk-based manner so as to verify the compliance with and operation of this policy and any applicable laws and regulations.

7.Action for the Violation

1. In case that violation of this policy is detected or expected, Toyobo Group will strictly undertake an internal investigation and fully cooperate with investigations to be conducted by relevant authorities.
2. In addition to the legal liability to be individually owned by the director, officer and employee of Toyobo Group who violated the corporate regulations including this policy, Toyobo Group will take strict action against such person in accordance with relative internal rules applicable to the violation.

*Applicable anti-bribery laws and regulations means as follows (for example)

• Japan: Unfair Competition Prevention Act, National Public Service Ethics Act
• United States of America: Foreign Corrupt Practices Act
• United Kingdom: U.K. Bribery Act 2010
• People's Republic of China: Unfair Competition Prevention Act

*Public Official, etc. mean as follows:

• a person engaged in public services of a national or local government.
• a person engaged in the affairs of government organization.
• a person engaged in a government enterprise, national and public university, hospital, etc. or any other organization owned or controlled by them.
• a person engaged in the public services of a court or other judicial institution.
• an officer or employee of the enterprise which special rights or interests are granted from national or local government.
• an officer and employee of a political party.
• a candidate for a public office.
• a person engaged in public services of an international organization.
• a person entrusted from the authority of national or local government or international organization.
• any other person equivalent to the above.

*money and any other profit means not only property benefits but also satisfying people's demand and desire enough

December 1, 2019
Toyobo Co., Ltd.
Compliance Committee Chairperson