SANKI ENGINEERING CO.,LTD

Environmental and CSR Activities

Compliance Declaration / Conduct Standards

Sanki Engineering Group Compliance Declaration

Established on October 21, 2013

One of the most important things for business activities of the Company Group is the policy under which the group will develop its business activities in compliance with applicable laws and regulations and in terms of the corporate ethics, and such policy is also provided for in the Sanki Engineering Group Code of Conduct and Action Guidelines.
The policy also applies to bidding activities, and thus the Code of Conduct 3 provides that "in seeking to win contracts, we will observe the rules of fair market competition."
However, under the recent changing circumstances surrounding companies, the Company hereby establishes the Sanki Engineering Group Conduct Standards to clarify the foregoing.
The important point in tendering a bid is to act as a fair and free competitor and to act at the sole discretion of the Company. The Company must strictly refrain from conducting any act that is influenced by the intentions of other companies or influences the acts of other companies. Prior to the submission of a bid, no discussion, arrangement or any act of a similar nature with other bidders is required and is deemed to be in violation of the Company's policy.
In witness whereof, all executive officers and employees of the Sanki Engineering Group declare that they shall comply with matters listed in the Sanki Engineering Group Conduct Standards in good faith, as a Company policy.

Sanki Engineering Group Conduct Standards

Established on October 21, 2013

  1. No discussion, information exchange, arrangement or decision with respect to the following shall be made among business operators:
    (1) Selecting method of a prospective winning bidder
    (2) Prospective winning bidder
    (3) Bidding price
    (4) Quoted price
    (5) Intention to win a bid, business performance, actual bid winning performance, number of bid nominations, etc.
    (6) Current award volume and remaining capacity for further bidding
  2. When attending a meeting or any other gathering among peers from different business operators, an employee of the Company shall obtain the prior approval of his or her superior. In addition, after the meeting or any other gathering, the employee shall write up brief minutes of the meeting and report to the superior on it.
  3. If an employee may have come to know that matters related to any item listed in Paragraph 1 are part of the agenda of a meeting or any other gathering among peers from different business operators, the employee shall not attend the meeting or any other gathering.
    If such matters are about to become part of the agenda during the meeting or any other gathering, the employee shall immediately leave such meeting and thereafter write up brief minutes of the meeting including that fact and report to his or her superior on it.
  4. Deciding the selecting method of a prospective winning bidder, the prospective winning bidder or the bidding price will be deemed to be in violation of the Anti-Monopoly Act even if such decision is made according to the direction or request of the ordering public agency. Therefore, no employee shall follow such decision.
  5. When a joint venture is formed to participate in a bid, no negotiation or information exchange with a business operator on the formation of the joint venture shall be allowed if the business operator is not likely to be involved in such joint venture.
  6. A winning bidder and other bidders shall not make any business arrangement that will be deemed to be subcontracting or profit giving with respect to a property for which the winner has made a successful bid, since such arrangement may be considered to be made in the context of bid rigging.
  7. No prevention or exclusion of other business operators from participating in a bid, or compulsion to other business operators to decline submitting a bid shall be carried out.
  8. These Standards shall apply to the following cases:
    (1) Where a trade association itself participates in a bid; and
    (2) Where an ordering public agency enters into a contract by submitting quotations of several business operations.
  9. In being involved in the business activities of the Company, if an employee discovers a fact or information that bid rigging may have been taken place, the employee shall report to his or her superior, or notify the contacts (Corporate Ethics Hotline) of that fact or information whether or not the employee is directly involved therein.
  10. Any question arising in connection with the application of these Standards shall be determined in accordance with the Guideline under the Antimonopoly Act on Activities of Business Operators and Trade Associations concerning Public Bidding, which was enacted by the Japan Fair Trade Commission on January 1, 2010.

Supplementary Provision
These Standards shall come into effect on October 21, 2013.

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