Under this policy, officers and employees, etc., of the ENEOS Group, both inside and outside of Japan, are required to comply with laws on the prevention of corrupt practices in Japan and other countries and prevent corrupt practices as well as actions complicit in corrupt practices.

The ENEOS Group complies with applicable laws and regulations in the countries and regions where it conducts its business activities.

The ENEOS Group prohibits, both directly and indirectly, corrupt practices along with actions complicit in corrupt practices among its officers and employees, etc., both inside and outside of Japan, regardless of whether the other party is a public servant or a private individual.

In cases where officers and employees, etc., of the ENEOS Group provide money or other benefits to third parties involved in business execution processes, the ENEOS Group will appropriately retain evidence of such transactions, and require that the money or other benefits be recorded in accounting records, accurately and without exception, in terms of amount, accounting item, etc., in order to prevent off-the-books handling.

The ENEOS Group will provide appropriate training to its officers and employees, etc., to ensure that this policy is appropriately implemented in the business activities of all ENEOS Group companies.

The ENEOS Group will impose rigorous penalties on any of its officers or employees, etc., found to be in violation of this policy, based on the rules of the ENEOS Group company the officer or employee belongs to. In addition, the ENEOS Group will impose rigorous penalties on advisors, consultants, agents, or contractors, etc., hired by the ENEOS Group if they are found to be in violation of this policy.

The presidents of all ENEOS Group companies bear a responsibility to ensure that their officers and employees, etc., abide by this policy. In addition, officers or employees, etc., of the ENEOS Group who detect any action that violates or could violate this policy are required to report such action immediately to their company.

This policy applies to all officers and employees, etc., of the ENEOS Group. All business partners involved in the ENEOS Group’s business activities will be requested to cooperate with this policy.

This policy supplements the provisions of the ENEOS Group Philosophy and the ENEOS Group Code of Conduct.

Notes

ENEOS Group:

ENEOS Holdings and the subsidiaries of ENEOS Holdings, including both those directly and indirectly owned.

Corrupt practices:

Bribery, embezzlement, coerced benefit sharing, bid-rigging and other acts that involve the abuse of the authority or position of oneself or a third party.

Bribery:

Refers to both giving bribes, where money or other interests or benefits are offered, promised or actually given, and receiving bribes, where interests or benefits are requested or actually received, for the purpose of obtaining interests or benefits by wielding improper influence over the duties of the other party.

Actions complicit in corrupt practices:

Actions including judicial interference, concealment of corrupt earnings, money laundering, and instigation, assistance or conspiracy to commit corrupt practices.

Employees, etc.:

Employees, contract workers, and part-time employees of the ENEOS Group, temporary workers dispatched to the ENEOS Group, and other persons subject to the instructions or orders of the ENEOS Group.

Public servant:

Includes, but is not limited to, national government employees, local government employees, persons engaged in official duties for international institutions, persons deemed to be engaged in public duties per laws and regulations, and officers and employees of companies effectively controlled by a national government or local government.