Our General Policy/ Efforts
AOI TYO Group (the “Group”) is committed to conducting all aspects of its business in keeping with the highest legal and ethical standards, and as part of our efforts to maintain similar standards for all employees and other persons acting on its behalf, we have established “Anti-Corruption, Anti-Money Laundering, and Economic Sanctions Compliance Policy” (the “Policy”). This Policy applies to all individuals working for the Group, including senior managers, officers, directors, employees (whether full-time, fixed-term, or temporary), consultants, contractors, or any other person associated with the Group (collectively “Employees”). We have established “Third Party Due Diligence Policy” (the “Third Party Policy”) (collectively with the Policy, the “Policies”) to ensure that third parties acting on the Group’s behalf should also adhere to the principles set forth in this Third Party Policy.
Our Anti-Corruption Policy
Employees must conduct their activities in full compliance with the Policies, the laws of their country of residence, the laws of the country in which they are employed, and the laws of other jurisdictions where the Group conducts business. Employees are not permitted to give or offer anything of value, directly or indirectly, to any government official (including his or her family members) or any commercial party for the purpose of improperly obtaining or retaining a business advantage. “Anything of value” should be broadly interpreted to include cash, gifts to family members, forgiveness of a debt, loans, personal favors, entertainment, meals and travel, political and charitable contributions, business opportunities, and medical care, among other items. Employees also may not solicit nor accept such payments or improper benefits.
Our Anti-Money Laundering Policy
The Group is committed to preventing its operations from being used for money laundering and terrorist financing. In order to ensure the Group does not enter into a transaction that may trigger the application of anti-money laundering laws, Employees are generally prohibited from accepting or rendering any cash payment for any services rendered or products sold. Third parties who request unusual payment methods are dealt with in accordance with the Policies.
Our Economic and Trade Sanctions Policy
Employees must conduct their activities in full compliance with all potentially applicable economic and trade sanctions laws.
Compliance Procedures Certification and Training
As part of the Group’s ongoing commitment to anti-corruption, anti-money laundering, and economic sanctions compliance, all Employees have certified that they are familiar with the contents of and agreed to observe and follow the Policy. In addition, the Group will offer periodic, risk-based training to educate Employees about the requirements and obligations of applicable laws and the Policies.
AOI TYO Holdings Inc.