SANKI ENGINEERING CO.,LTD

SUSTAINABILITY

Compliance Declaration / Conduct Standards

Sanki Engineering Group Compliance Declaration

Formulated: October 21, 2013

A policy of conducting business activities in compliance with laws and regulations and based on corporate ethics is the major premise behind the operations undertaken by the Sanki Engineering Group, and is set forth in the Sanki Engineering Group Code of Conduct and Action Guidelines.
Activities related to the granting of contracts are also subject to this and the third provision of the Code of Conduct stipulates, "In seeking to win contracts, we will observe the rules of fair market competition."
Nonetheless, we have formulated the Sanki Engineering Group Behavioral Standards in order to clarify the above points in line with changes in the environment surrounding the Company in recent times.
Essential components of bidding for any contract include acting as an honest and fair competitor, or in other words, acting in accordance with the independent judgments of the Company. Employees must strictly refrain from behavior swayed by the intentions of other companies or that impacts the actions of another company. When bidding for a contract, it is unethical to talk with other bidders or take action to force an adjustment, actions which breach the Company's policy.
Accordingly, we declare as Company policy that all Sanki Engineering Group executive officers and employees shall comply faithfully with the items stipulated in the Sanki Engineering Group Behavioral Standards.

Sanki Engineering Group Behavioral Standards

Formulated on October 21, 2013
Revised on April 1, 2015
Revised again on January 1, 2016

  1. No discussion, exchange of information, adjustment, or decision upon the following between businesses shall take place.

    1. Method of selecting prospective candidates for a contract
    2. Prospective contract candidates
    3. Bidding price
    4. Estimated price
    5. Eagerness for contract, results of sales activities, contract results, number of times nominated, etc.
    6. Order amount in stock, order reserve
  2. Approval shall be gained from your superior before attending a meeting between businesses in the same industry. Following the meeting, record of the content must be made and shall be reported to your superior.
  3. Such meetings shall not be attended if knowledge has been obtained in advance that the topic of the meeting between businesses will concern a matter related to any of the items in Provision 1 above. Furthermore, if the topic turns to such a matter during the course of the proceedings, you must immediately leave the meeting and the fact must be noted and reported to your superior.
  4. Even when decisions on method of selecting prospective contract candidates, prospective contract candidates, or bidding price are made based on the guidance or at the request of the public office offering the contract, you must not adhere to this since it is a violation of the Anti-Monopoly Act.
  5. When setting up a joint-venture group to participate in a tender bid, you must not negotiate or exchange opinions regarding the formation of said group in a manner that includes persons aside from those that may be involved as partners.
  6. A subcontractor transaction or transaction that may be seen as giving benefits must not be undertaken between the successful tender bidder and another participating bidder for a property since this may lead to suspicions of bid-rigging in the background.
  7. Actions that in any way hinders or excludes participation in a bid on the part of other businesses or force another business to withdraw from a bid shall not be taken.
  8. These standards shall apply to the following cases as well.

    1. When a trade association acts as agent
    2. When the public office offering the contract offers an agreement based on a method of estimate adjustment
  9. In the case that you come into contact with a fact or information that suggests the existence of bid-rigging in the Company's business activities, you must report this to your superior or via the reporting system (Fair Trade Hotline), irrespective of whether or not it concerns you.
  10. In the case that a doubt arises over the application of these standards, you shall make judgment based on the “Guidelines Concerning the Activities of Firms and Trade Associations with Regard to Public Bids” (Public Bidding Guideline) issued by the Japan Fair Trade Commission on April 1, 2015.

Additional clause: These standards shall be implemented as of January 1, 2016.