To reinforce our commitment to Fair Trade and Prevention of Corruption — as established in the CTC Group Code of Conduct — we have instituted this policy to address the complexities of modern global business and evolving regulations.
We pledge, together with our business partners, to strictly comply with all applicable laws and regulations in every region where the CTC Group operates. We remain dedicated to doing our utmost to promote a fair trading environment and prevent corruption in all its forms.
We will promote fair trade, and never engage in any conduct that impedes fair competition, such as coordinating orders or adjusting the price of services or products, etc. with competitors, whether in Japan or overseas.
For the purpose of preventing corruption, we will not provide, propose or promise any entertainment, gifts, or other facilities to public officials or persons in equivalent positions, or other business partners for the purpose of obtaining illegal benefits, whether in Japan or overseas. In addition, we will not cause our business partners to conduct such bribery.
We will appropriately develop and operate a system of personnel, organization, and internal rules, necessary for ensuring the observance of the preceding two clauses, by understanding the risks of each CTC Group company.
We will monitor the system of personnel, organization, and internal rules in the preceding clause on a regular basis, including whether it is appropriately established and operated, and whether its function is effective. In addition, we will review and improve the system as necessary, in light of the status of risks or the revisions of laws and regulations.
We will implement this policy and ensure that this policy and the related efforts of each CTC Group company are continuously disseminated.
First edition: September 1, 2020
Revised: October 1, 2024
Tatsushi Shingu
President and CEO
ITOCHU Techno Solutions Corporation