Policies and Frameworks

Anti-Bribery Regulations (Summary)

  1. Sysmex prohibits any conduct that may lead to bribery and facilitation payments. *1 “Bribe” refers to any tangible or intangible benefit*2, including cash, etc., provided, offered, or promised as an undue reward in connection with another person’s duties (e.g., for the purpose of the acquisition or maintenance of business or preferential treatment in business*3).
  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. It is permissible to receive hospitality or gifts from third parties, such as business partners, provided that such gestures are moderate in nature. 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.
  • 1 Permissible extent: where Group Officers and Employees receive any demand suspected to be for the provision of a Bribe or undue benefit and failure to comply with said demand would reasonably risk death or injury to them.
  • 2 This includes benefits provided in various forms or under different names such as cash and cash equivalents, loans and securities, gifts and hospitality, donations, grants, sponsorships, rebates, discounts, kickbacks, and various services such as employment, education, medical treatment, and other opportunities.
  • 3 Evading or omitting administrative procedures, acquiring or maintaining opportunities for transactions, obtaining an advantage in a competitive bidding process, obtaining confidential information, etc.