Anti-Bribery Regulations (Summary)

1. Sysmex shall not, directly or indirectly, provide, offer, or promise a bribe to any party (hereinafter “bribe” shall mean any tangible or intangible benefit, including cash, etc., provided, offered, or promised as an undue reward in connection with another person’s duties, including, but not limited to: cash and cash equivalents; loans and securities; gifts, hospitability and entertainment; charitable donations, scholarship donations, political grants and sponsorships; rebates, discounts and kickbacks; and employment, education, medical treatment opportunities and services of any other kind.), nor shall it authorize any such acts. Facilitation payments are also prohibited.
2. Before initiating a new transaction or carrying out a merger or acquisition, Sysmex will not only conduct regular examination on the identity, backgrounds, and business activities of the counterparty but also investigate other items, including its relationships with Public Officials and past involvement in bribery incidents.
3. Sysmex prohibits any payment to a business partner, etc. if it is known or suspected that the said payment will be provided as a Bribe.
4. Sysmex prohibits Group Officers and Employees from soliciting, receiving, or promising to receive a bribe in connection with their duties, as well as from accepting entertainment or gifts that exceed moderation. However, it is permissible to receive entertainment or gifts from business partners and other third parties within the bounds of moderation. Upon receipt, immediate documentation shall be made in accordance with the procedures as directed by the compliance officer.
5. Sysmex shall establish and operate systems of periodic education and training concerning prevention of bribery for Group Officers and Employees.
6. Group Officers and Employees who become aware of any actual or suspected violation of the Regulations shall report it to the compliance officer immediately.

This Regulation has been approved by the Executive Officer in charge of Legal Affairs.