Global Digital Transformation Partner

The Company strictly prohibits the offer, proposal or promise of benefits such as improper entertainment and gifts to government officials or persons with similar status. In addition, the Company ensures that the amount, frequency and extent of benefits such as entertainment, gifts and donations accepted by the Company or provided to business partners and other parties are limited to the scope judged to be adequate under socially accepted conventions. Furthermore, the Company strictly prohibits employees from engaging in corrupt practices such as obstruction of justice and money laundering through Company or third-party channels. These rules are thoroughly communicated to employees through annual training sessions.

• 1. The executives and staff members of transcosmos Group shall comply with and be fully aware of the laws/regulations governing the prevention of bribery & corruption in the country/area where they carry out business activities.
• 2. The executives and staff members of transcosmos Group shall refrain from accepting or receiving benefits directly/indirectly beyond the scope judged to be adequate given the local laws, guidelines or social customs of the country/area where they carry out business activities when contacting people including government officials.
• 3. The executives and staff members of transcosmos Group shall record all items of business income and expenditure accurately and adequately in the accounting ledger and recordkeeping.
• 4. The executives and staff members of transcosmos Group shall report an act not complying with these Basic Policies or the law on the Prevention of Bribery & Corruption immediately to the competent department including the desk for whistleblowing, etc.
• 5. The transcosmos Group shall deal with employees running afoul of these Basic Policies strictly per the Company’s in-house regulations.

transcosmos Group is committed to comply with the Political Funds Control Act of Japan as well as political finance laws and regulations of respective countries and regions when making political contributions.
The total amount of political contributions transcosmos inc. made in Japan in FY2024/3 was \2 million.