Basic Policy on the Prevention of Bribery and the Provision of Entertainment and Gifts
April 1, 2026
Tokyo Parts Industrial Co., Ltd.
President and Representative Director: Hiroyuki Teshima
Tokyo Parts Industrial Co., Ltd. (hereinafter, “the Company”) hereby establishes this Basic Policy based on our Compliance Regulations, recognizing that adherence to all applicable laws and acting with high ethical standards and fairness by all officers and employees are essential for earning the trust of society and enhancing corporate value.
Chapter 1: Gifts and Entertainment Provided to Public Officials
- Prohibition of Gifts to Public Officials
We shall not provide, offer, promise, or approve any improper benefit to public officials (including individuals scheduled to become public officials and “deemed public officials”), nor to foreign public officials (collectively referred to as “Public Officials”), in connection with their duties.
We also shall not provide mid-year or year-end gifts to Public Officials.
“Deemed public officials”: Individuals regarded as public officials under specific laws (e.g., employees of national university corporations, Japan Post Group companies).
“Foreign public officials”: Bribery of foreign public officials is prohibited under the Unfair Competition Prevention Act (Article 18).
- Exceptional Cases Where Gifts May Be Permitted
Notwithstanding the above, we understand that gifts to Public Officials that are unrelated to their duties and fall within socially accepted norms of courtesy may be exceptionally permitted.
If unsure, we shall consult with the General Affairs Department.
- Prohibition of Entertainment for Public Officials and Exceptions
We shall not provide meals, entertainment, or hospitality—such as dining or golf—to Public Officials.
However, exceptions may apply if both parties reasonably share the cost (“splitting the bill”) or in the case of standing-style receptions.
In such cases, we shall promptly notify the General Affairs Department afterward.
- Ensuring the Appropriateness of Political Contributions and Donations
When making political contributions or donations to organizations, we shall comply with the Political Funds Control Act and all other relevant laws to ensure appropriateness.
Chapter 2: Gifts and Entertainment Provided to Persons and Organizations Other Than Public Officials
- Gifts and Entertainment for Non–Public Officials
When giving gifts or providing entertainment to business partners or other individuals/organizations that are not Public Officials, we shall do so only to the extent necessary to build sound and positive business relationships and within the limits considered appropriate by social standards.
The purposes and acceptable limits shall follow separately established internal rules.
- Prohibition of Requesting Gifts or Entertainment
We shall not request or imply requests for gifts or entertainment from business partners or any other individuals or organizations that are not Public Officials.
- Receiving Gifts or Entertainment from Non–Public Officials
We shall not accept gifts or entertainment from business partners or other individuals/organizations that exceed socially acceptable norms.
The acceptable limits for the above shall follow separately established internal rules.