About Our Anti-bribery Policy

Prohibition of bribery (including facilitation payments) to public officials, etc.

Tenma Corporation and the Tenma Group, including its subsidiaries, do not permit any improper entertainment, gifts, favors, or other benefits, offers, or promises to public officials or persons in similar positions (hereafter “public officials, etc.”) whether in Japan or overseas. In the unlikely event that a public official or other person, whether domestic or foreign, should demand that we provide an improper benefit, the Tenma Group will firmly reject the demand and, depending on the circumstances, contact the relevant authorities.

Minor payments to public officials or similar for the sole purpose of facilitating procedures for standard administrative services (“Facilitation Payments”) may impede the efficient operation of government agencies, thereby undermining economic development and law. They are prohibited in many countries as they constitute a form of bribery of public officials or similar, and the Tenma Group entirely prohibits facilitation payments.

“Public officials, etc.” includes the following persons:

  • National government and local government officials, both domestic and foreign (including ministers, legislators, ambassadors, and military personnel)
  • Officers and employees of domestic and foreign government-run companies and government-affiliated corporations
  • Officers and employees of legal entities treated in the same manner as public officials under domestic and foreign laws and regulations
  • Officials and employees of international organizations (e.g., United Nations, World Trade Organization, etc.)
  • Officers and employees of businesses that perform inspections, tests, and other duties under the authority of domestic or foreign governments, local governments, or international organizations, to which they are delegated.
  • Political party officials, candidates for public office, etc.

“Entertainment, gifts, favors, and other benefits” includes the following items:

  • Money, money orders, gift certificates, loans, collateral, and guarantees
  • Invitations (sports games, plays, trips, etc.)
  • Contributions and sponsorship fees
  • Gratuities, rebates, promotional expenses, and discounts
  • Employment opportunities for individuals or their relatives

Thorough record management

We will prepare and maintain timely and accurate accounting records of all transactions and dispositions of assets.

Thorough dissemination of anti-bribery information

The Tenma Group will continue implementing various measures, including e-learning, training, and seminars with case studies throughout the group.

Internal reporting system

We will promote the introduction of dedicated internal reporting systems at all Tenma Group companies to identify and correct bribery and other forms of noncompliance at an early stage. We will introduce a consolidated and global-based whistleblower system for antitrust and bribery violations.