1.Purpose

The Maxell Group has developed its business activities in accordance with the principles of "Basics and Ethics" and "Morality over Profit". The Maxell Group has established this Anti-Bribery Policy in order to comply with all applicable national and regional laws and regulations that pertain to bribery and corruption in business activities, and to continue to maintain fair relationships with society by acting with a high sense of ethics.

2.Basic Policy

The Maxell Group complies with Japan's Penal Code, Unfair Competition Prevention Act, National Public Service Ethics Act, National Public Service Ethics Code, ethics codes established by local governments, Political Funds Control Act, US Foreign Corrupt Practices Act (FCPA), UK Bribery Act (UKBA), and other national or regional laws that pertain to bribery prevention, public service ethics, or related penalties (including laws that implement the OECD Anti-Bribery Convention and United Nations Convention against Corruption), and implements thorough actions aimed at preventing bribery and corruption involving public officials or persons other than public officials.
This Anti-Bribery Policy applies to all Maxell Group officers, company employees, contract employees, senior company employees, temporary members, part-time employees, employees on loan, and dispatched employees (hereinafter referred to as officers and employees of the Maxell Group).

3.Specific Action Guidelines

1. 1.　Prohibition of Bribery of Public Officials, etc.#1
   All officers and employees of the Maxell Group, whether in Japan or overseas, are prohibited from providing, offering, or promising money, goods, entertainment, gifts, benefits, or other advantages#2 in violation of the law to public officials or persons in an equivalent position (hereinafter referred to as public officials).
2. 2.Prohibition of Facilitation Payments (Prohibition of Payment for Facilitating Business Operations)#3
   All officers and employees of the Maxell Group, whether in Japan or overseas, are prohibited from making facilitation payments.
3. 3.　Prohibition of Bribery through Third Parties
   All officers and employees of the Maxell Group, whether in Japan or overseas, are prohibited from instructing the bribery of public officials via a third party (agent, advisor, consultant, representative, agency, distributor, reseller, outsourcing company, contractor, or other business partner who collaborates with the Maxell Group, or officer, employee, or subcontractor of such) or from tacitly approving the bribery of public officials via a third party.
4. 4.　Provision of entertainment and Gifts to Customers, etc. Other than Public Officials, etc.
   All officers and employees of the Maxell Group, whether in Japan or overseas, are prohibited from providing money, goods, entertainment, gifts, benefits, or other advantages even to customers who are not public officials, unless such provision is not for the purpose of gaining unfair (illegal) business advantages, is in compliance with the laws and regulations of each country and region, and is within a reasonable range deemed socially acceptable.
5. 5.　Acceptance of entertainment or Gifts
   All officers and employees of the Maxell Group, whether in Japan or overseas, are prohibited from accepting excessive entertainment and gifts that exceed social norms.
6. 6.　Thorough record management
   All officers and employees of the Maxell Group are prohibited from engaging in off-balance-sheet transactions, fictitious transactions, and other false transactions. Furthermore, all transactions and asset dispositions (including payments to public officials) must be accurately recorded in the account books in a timely manner, and related materials must be retained.
7. 7.　Thorough awareness raising and enlightenment of bribery prevention
   In order to thoroughly prevent bribery and corruption, the Maxell Group will develop and implement a bribery prevention system that is appropriate for the conditions at each Group company, and will continuously raise awareness through training and Corporate Ethics Month activities periodically implemented each year within the Maxell Group.
8. 8.　Internal whistleblowing System
   The Maxell Group will introduce and operate a global internal reporting system that will enable all officers and employees of the Maxell Group, whether in Japan or overseas, to directly report to an internal hotline in Japan. The aim is to detect and correct compliance violations (including bribery and corruption) at an early stage, and enhance the self-governance function within the organization.

#1: Examples of public officials
- National and local government representatives and staff, both in Japan and overseas
- Political party officers and staff, and candidates for public office (including persons not currently in office)
- Professors, teachers, and staff who are employed by a national or public educational institution
- Doctors, nurses, and medical office staff who are employed by a national or public medical institution
- Officers and staff of an international organization
- Officers and staff of a company or service provider that has received authority as a designated inspection agency to perform inspections and other business affairs implemented by a national or local government (in Japan or overseas) or international organization
- Officers and staff of a public association, fund, or organization

#2: Examples of money, goods, entertainment, gifts, benefits, or other advantages
Money, cash voucher, cashable gift card, entertainment, gift of property or goods, loan, guarantee, provision of security or collateral, invitation (to sporting events, theater performances, trips for leisure, etc.), donation, honorarium, rebate, promotional payment, discount, or job opportunity for the individual concerned or their family

#3: Facilitation payments
Prohibited by the Maxell Group, these are small payments made to facilitate or expedite normal administrative service procedures for things such as visa and work permit approvals, customs clearance, inspections, water and sewage, telephone, and electric installation. They are given to public officials who have no discretionary power, and are made without any relevant legal basis. However, such payments may be permitted in exceptional cases, such as when someone's life or health is in imminent danger (due to violence, threat, restraint, confinement, etc.). Furthermore, if facilitation payments are demanded by a public official, the Maxell Group will examine ways to eliminate the facilitation payments, including seeking improvement from the local government through the local Japanese Embassy or Consulate, chamber of commerce, JETRO, or other such organization.