ANTI-BRIBERY POLICY

1. Purpose

KADOKAWA CORPORATION and its subsidiaries and affiliates (collectively the “KADOKAWA Group”) hereby establish this anti-bribery policy (the “Policy”) as a fundamental policy to enhance the KADOKAWA Group’s legal compliance framework and uphold high ethical standards in accordance with the KADOKAWA Group Compliance Policy. The objective of the Policy is compliance with the laws and regulations, etc. pertaining to the giving or receiving of bribes (“Bribery”) that may arise in connection with the KADOKAWA Group’s business activities (“Laws and Regulations”).

2. Compliance with Laws and Regulations

The members of the KADOKAWA Group’s Board of Directors, its Chief Officers,  Auditors, Corporate Officers, Senior Advisors, Advisors, and employees (including limited-term employees and temporary staff members from staffing agencies) (“Officers and Employees”) will adhere to the Laws and Regulations related to the prevention of Bribery that apply in their countries and regions.

3. Prohibition of Bribery

  1. The KADOKAWA Group’s Officers and Employees will not, directly or indirectly, provide, offer, promise, or approve any bribes or improper benefits to public officials to obtain inappropriate favors from them.
  2. The KADOKAWA Group’s Officers and Employees will not provide entertainment or gifts to public officials, or cover their travel expenses, etc. except in cases where such entertainment is conducted for legitimate business purposes and remains within appropriate limits of social courtesy.
  3. In addition to the above, the KADOKAWA Group’s Officers and Employees will not engage in any activities that could be considered Bribery.

4. Maintaining records in accounting books

The KADOKAWA Group’s Officers and Employees will prepare and maintain accounting books, etc. and other records accurately and appropriately based on factual information.

5. Cooperation with audits and investigations

The KADOKAWA Group’s Officers and Employees will fully cooperate with audits conducted by Auditors, etc. and investigations by the accounting auditor, the internal audit department, the legal department, and relevant authorities. They will be accountable for complying with the Policy.

6. Framework development

To prevent Bribery and to detect it at an early stage, the KADOKAWA Group will set up a contact point for reporting any conduct that violate or may violate the Policy and for consulting the contact point regarding such conduct. Additionally, it will establish specific procedures to ensure compliance with the Policy.  

7. Education and training, etc.

The KADOKAWA Group is committed to preventing Bribery by ensuring that all Officers and Employees are aware of the Policy through education and training. Additionally, the KADOKAWA Group will work to gain the understanding and cooperation of its business partners in these efforts.

8. Actions taken in the event the Policy is violated

The KADOKAWA Group will take strict action against any Officer or Employee who violates the Policy in accordance with internal rules and regulations and will work to prevent future violations.

Established: January 1, 2024