Sapporo Group Anti-Bribery and Anti-Corruption Policy

This policy applies to all officers and employees of Sapporo Group.
Sapporo Group also expects third parties, such as business partners, distributors, consultants, and joint venture partners, to conduct themselves in a manner consistent with the spirit of this policy.

Sapporo Group prohibits the following acts:

To ensure accountability for its compliance with applicable anti-bribery laws and regulations and this policy, Sapporo Group accurately records relevant transactions and expenditures in its books and records based on the underlying facts under a sound internal control system. It also retains the related documents in accordance with applicable internal rules of Sapporo Group companies.

Sapporo Group maintains an effective anti-bribery framework designed to prevent corrupt practices. This includes establishing relevant internal rules and procedures and communicating them throughout the Group.
Before entering into a new business relationship, Sapporo Group conducts appropriate screening of the prospective counterparty, including a credit check as necessary. When considering acquisitions, mergers, joint ventures, or similar transactions, Sapporo Group also investigates and reviews the relevant counterparties in advance, including by conducting due diligence on bribery risks, as necessary.

To prevent misconduct, including bribery and other corrupt practices, detect such misconduct at an early stage, and prevent the resulting harm from escalating, Sapporo Group has established an internal reporting and consultation system through which officers and employees can promptly report concerns or seek advice.
Sapporo Group does not tolerate adverse treatment or retaliation against anyone who reports concerns, seeks advice, or cooperates in an investigation. Sapporo Group is committed to maintaining an environment in which people can speak up safely.

Sapporo Group provides ongoing education and awareness training on corruption prevention to officers and employees, helping them understand the policy and apply it in practice.
Sapporo Group also monitors how this policy is being applied and reviews it as necessary.

Sapporo Breweries receives reports from Sapporo Group companies on the status of their anti-corruption initiatives under this policy, reports regularly to the Board of Directors, and oversees the implementation of those initiatives.
Sapporo Group also works to continuously enhance and improve its corruption prevention framework across the entire group.

Any violation of this policy or any applicable law, regulation, or internal rule by an officer or employee will be subject to strict action in accordance with the internal rules, employment regulations, and other applicable provisions of the relevant group company.
If Sapporo Group becomes aware of facts suggesting that a third party may have been involved in corrupt practices or that a violation may have occurred, it will promptly investigate the circumstances and take appropriate action.