Anti-Bribery and Anti-Corruption Policy

This Policy applies to all executives and employees of the Mitsubishi Logistics Group. The Group also requires all business partners involved in its business operations to understand and comply with this Policy.

Mitsubishi Logistics Group companies and their executives and employees comply with all applicable laws and regulations prohibiting acts of bribery and any other forms of corruption.

The Mitsubishi Logistics Group has zero tolerance for providing, offering, or promising any improper hospitality or entertainment, gifts, benefits, or other unfair advantages to public officials or persons in equivalent positions (referred to in this Policy as “Public Officials”), private individuals, or private businesses. The Group also prohibits corrupt practices, including but not limited to receiving, demanding, or accepting promises of any improper hospitality or entertainment, gifts, benefits, or other unfair advantages from third parties.

The Mitsubishi Logistics Group does not engage in bribery through agencies, agents, consultants, or other third parties (referred to in this Policy as “Agencies”). When selecting Agencies, Group companies conduct appropriate due diligence, including confirming that Agencies have no conflicts of interest involving foreign Public Officials. Group companies do not provide any benefits to, nor receive any benefits from, Agencies where such benefits could or may be used for bribery.

The Mitsubishi Logistics Group has zero tolerance for unfair business practices, including bid rigging and cartels; money laundering and terrorism financing; acts that pursue personal interests (whether one’s own or those of a third party) in conflict with the interests of the Group; and all other forms of corruption.

Mitsubishi Logistics Group companies accurately record all transactions and disposal of assets in a timely manner and maintain such records appropriately.

The Mitsubishi Logistics Group conducts regular internal audits to monitor compliance with laws and regulations prohibiting bribery and other forms of corruption, as well as this Policy.

The Mitsubishi Logistics Group uses its internal reporting system, which ensures confidentiality and anonymity, to quickly detect any violation or potential violation of this Policy, conducts the appropriate investigation, and implements corrective actions.

Mitsubishi Logistics Group companies establish the internal structure required to comply with applicable laws and regulations, guidelines prohibiting bribery and other forms of corruption, and this Policy, and regularly review the effectiveness of this structure and make improvements as necessary. The Mitsubishi Logistics Group also conducts education and training on preventing bribery and other forms of corruption for Group executives and employees.

Any executive or employee of Mitsubishi Logistics Group companies who violates this Policy is subject to disciplinary action in accordance with the company’s employment regulations and other applicable rules.