POLICY Preventing Corruption and Bribery

We will practice ethical and honest behavior based on the “Sugino Machine Group Code of Conduct and Standards,” and comply with anti-bribery laws and regulations applicable in each country and region, as well as internal company regulations.

1.We shall not engage in acts of bribery, embezzlement, coercion of providing benefits, fraudulent bidding, or any other misuse of one’s power or position for personal or third-party gain. We firmly refuse to participate in such activities, including obstruction of justice and money laundering.

1.We shall not offer, promise, or give bribes, whether directly or indirectly, to anyone, nor shall we accept bribes.

2.We shall not engage in bribery or corrupt practices to obtain unfair benefits from public servants, organization employees, politicians, or any other similar individuals (hereinafter referred to as ‘public officials, etc.’).

1.We shall establish a framework in which executives, employees, and business partners can promptly consult and report to the compliance department designated by each Sugino Machine Group company in the event of suspected violations of anti-bribery laws or this policy.

1.To prevent bribery directed toward public officials, etc., through business partners, we will conduct a screening of business partners at the beginning of transactions. Additionally, we will perform due diligence on counterparties in the case of acquisitions, mergers, and joint ventures.

1.To fulfill our accountability for compliance with anti-bribery laws and this policy, we will record accounting entries accurately based on facts and properly retain relevant documents.

2.We will regularly conduct self-assessments of compliance with this policy and respond promptly to any reports or investigation requests from internal audits or relevant authorities in various countries and regions. Additionally, we will periodically review this basic policy and its compliance procedures, making revisions and improvements as necessary.

1.In the event that executives, employees, or others violate anti-bribery laws and this policy,we will rectify the violation and impose strict penalties in accordance with internal regulations and procedures.