Shiseido Group Policy on Anti-Corruption

Shiseido Group (“Shiseido”) hereby establishes the Shiseido Group Policy on Anti-Corruption (the “Policy”) by which it will promote efforts to ensure anti-corruption measures and fulfill its social responsibilities.

The Policy will apply to all executives, specifically defined as Directors, Corporate Executive Officers, Executive Officers, and Audit & Supervisory Board members, and employees of Shiseido. Shiseido also will require its business partners relating to Shiseido’s products and services to comply with the Policy.

Shiseido does not give, offer, or promise a bribe, in any form, to any person, whether direct or indirect, nor will it receive, request, or promise to receive any kind of a bribe, irrespective of the name given to it, including without limitation political contributions, donations, charitable activities, sponsorship activities, and kickbacks. Shiseido prohibits all of its executives and employees from engaging in the activities above.
In addition, executives and employees of Shiseido may not provide entertainment or gifts to anyone except when entertainment or a gift is provided within social norms, as permitted by laws and regulations, and in accordance with internal rules.

Shiseido engages in the measures below to prevent bribery, and continues to promote and enhance such measures in implementing the Policy.

Shiseido has developed and implemented an effective system for the prevention of bribery, including the development of relevant internal rules and procedures, to ensure the thorough prevention of bribery. The measures include the Framework of Empowerment, credit checks on new accounts, and due diligence in acquisitions.

Shiseido offers education and training to all of its executives and employees for purposes of preventing bribery, such as familiarizing such executives and employees with the Policy and relevant internal rules.

Shiseido periodically evaluates bribery risks and monitors the status of operation of the system for the prevention of bribery, and reviews and improves measures relating to, and control of, the prevention of bribery as required with respect thereto.

Shiseido makes and keeps records all transactions and assets accurately and fairly, and in reasonable detail, in its accounting books and records, to thoroughly prevent bribery and to fulfil accountability therefor.

Shiseido complies with the laws and regulations and the rules relating to the prohibition against bribery that are applicable in the countries and regions where it conducts its business activities, including the Foreign Corrupt Practices Act in the U.S., the Bribery Act in the U.K., the commercial bribery rules in the PRC, and the Unfair Competition Prevention Act in Japan.

If it is suspected that any executive or employee of Shiseido has committed a violation of laws, regulations or rules prohibiting bribery, or other internal rules, including the Policy, Shiseido will investigate the situation immediately and endeavor to determine the facts.
If an executive or employee of Shiseido becomes aware of the existence of, or suspects, such a violation, the relevant executive or employee shall make a report to Shiseido immediately, in accordance with internal rules.
If Shiseido determines that a violation has occurred, Shiseido will analyze the root cause, take remedial measures, and take strict action against the executive or employee who committed the violation, based on the internal rules.