Ethics & Compliance

Ethics & Compliance

SDG-related Initiatives

10.Reduced Inequalities

10.Reduced Inequalities

CSV Goals (Creating Shared Value) *The base year is 2015 and the target year is 2025 unless otherwise noted.

Human rights
  • 100% : Adherence to Supplier Guiding Principles across the Coca-Cola Bottlers Japan Holdings Inc. Group value chain
Procurement
  • 100% : Sustainable sourcing

Ethics and compliance policies

In order to be a sustainable business, the Coca-Cola Bottlers Japan Holdings Inc. Group (CCBJH Group) must fulfill its social responsibilities and every individual employee should always act with dignity. As part of this, we have enacted the Code of Business Conduct and Ethics, and promote a corporate culture that emphasizes ethics and compliance.
The Code of Business Conduct and Ethics covers five areas: acting righteously with dignity, right conduct,respect of human rights, dealing with stakeholders, and conflicts of interest. All employees are expected to observe all laws and regulations as well as the Code, internal rules, and workplace principles. They are also expected to act with integrity and honesty, to think before acting, and to seek guidance when in doubt.

Ethics & Compliance Reporting Hotline

We have set up the Ethics & Compliance Reporting Hotline (a dedicated email address and telephone number), with points of contact in-house and at an external legal counsel's office, to accept requests for consultation about matters that conflict with, or may conflict with, the Code of Business Conduct and Ethics. Anonymous consultation is available, and we are striving to raise awareness of the hotline and create an environment that facilitates consultation by a variety of means, such as issuing ethics and compliance bulletins and posting the hotline points of contact on the Group intranet. Furthermore, we value the cooperation of employees who report issues that need to be addressed, and any form of retaliatory measures against reporting employees has been made a violation of the Code. We confidentially investigate any problem requiring examination under the Code, determine whether there has been a violation of the Code or laws and regulations, and take any appropriate corrective measures.

Compliance education

The standing CCBJH Group Ethics & Compliance Committee, which comprises members of the management team, meets on a regular basis and takes the lead in promoting activities that further foster and inculcate high ethical standards and compliance awareness among the Group's employees and encourage a corporate culture that places importance on ethics and compliance. These initiatives include the implementation of awareness and education activities, operation of the Ethics & Compliance Reporting Hotline, other responses to compliance-related incidents, and consideration and implementation of measures to prevent the reoccurrence of incidents.

Supplier Guiding Principles

We are committed to fully enforcing Supplier Guiding Principles The Coca-Cola Company sets, and expect our business partners (the Suppliers) who provide goods and services to us to develop and implement appropriate business processes to ensure compliance.

*P16 Post Assessment Follow-Up : Facility will be assessed in 3 years for Green.

Internal Control System Basic Policy

The following policies on internal control shall be set to ensure sound management and appropriate operations of the Company.

1. System to ensure that performance of duties by Directors and employees of Coca-Cola Bottlers Japan Holdings Inc. (hereafter to be referred to as “CCBJH”) and Group companies comply with laws and regulations and the Articles of Incorporation.
(1) The code of conduct shall be established in order to ensure that all the Directors, Executive Officers, and employees of CCBJH and Group companies (hereafter to be referred to as “Our Group”) comply with laws and regulations and the Articles of Incorporation to act in conformity with social norms. The Risk Management Committee shall be convened periodically in order to reinforce the compliance system and to prevent non-compliance.
(2) An internal whistle-blowing system against non-compliance, namely, a reporting and consultation contact separate from the reporting line to immediate managers, shall be set up.
(3) The oversight function of the Board of Directors shall be reinforced by adopting the company system where Audit and Supervisory Committee is established in order to ensure auditing by the Audit and Supervisory Committee where more than a half of the constituent members are External Directors.
(4) The department in charge of internal auditing shall be established in order to audit whether business activities are conducted appropriately and effectively in conformity with laws and regulations, the Articles of Incorporation, Company Rules and Regulations, etc.
(5) The Company clearly identifies the firm stance against anti-social forces and organizations that cause threats to the orders and safety of civil society and that the Company never ties with such entities. The Company shall never accede to any illegal request and deal with any such request in cooperation with the police. 

2. System to retain and manage information related to Directors’ performance of their duties  
 (1) The Company shall record information regarding minutes of General Shareholders meetings, minutes of Board of Directors meetings, documents and other materials related to important decision-makings and Directors’ performance of their duties in documents or electronic media and retain it in accordance with the Rules of Documentation Handling and Information Security Policy in a manner similar to that for statutory documents. 
(2) The Company’s Directors may inspect such documents, etc. at any time.

3. Regulations and other systems concerning loss risk management of Our Group
(1) In accordance with Our Group policy on responding to material business risks and from the viewpoint of management of other risks, significant items shall be reported to the Risk Management Committee, and the Risk Management Committee shall determine policies to accommodate the risks as required.
(2) The Company establishes rules/guidelines and maintains an organization to execute effective response to material risks, and ensure the matters to be passed down by establishing manuals and implementing training for the entire Group.
(3) The department in charge of risk management in the Company or its subsidiaries is to monitor the condition of company-wide risks, and take appropriate measures on a group-wide basis.

4. System to ensure efficiency of performance of duties by Directors of Our Group
(1) The Board of Directors shall determine Group-wide management policy and goals shared by the Directors, Executive Officers, employees and others of Our Group, and determine the efficient method to achieve the goals including the allocation of authority based on the group’s decision-making rules.
(2) In addition to Board of Directors Meetings, appropriate forums such as the Management Meeting shall be organized to deliberate significant matters affecting the entire CCBJI Group, thereby ensuring that decisions are reached based on considerations of multi-dimensional aspects.

5. System to ensure appropriateness of operations in a corporate group, which consists of the Coca-Cola Bottlers Japan Inc. and its subsidiaries
 The Company shall ensure management integration of Our Group through establishment of a corporate philosophy, management policy, code of business conduct and Chart of Authority common throughout Our Group and supervise and manage the performance of the subsidiaries’ operations.

6. Matters concerning employees assisting the Audit and Supervisory Committee to execute the duties if the Audit and Supervisory Committee request the assignment of such employees, matters concerning the independence of such employees from directors (excluding directors serving on the Audit and Supervisory Committee) and matters related to ensuring the effectiveness of instructions given by the Audit and Supervisory Committee to such employees
 The Company shall assign employees assisting the Audit and Supervisory Committee. Such employees shall execute the duties under the instructions given by the Audit and Supervisory Committee in assisting executions of duties by the Audit and Supervisory Committee and shall not receive instructions from directors(excluding directors serving on the Audit and Supervisory Committee).

7. System for reporting by Directors and employees of Our Group to the Audit and Supervisory Committee and systems to ensure that reporting parties do not receive disadvantageous treatment as a result of such reports
(1) Upon discovery of any incident that could cause Our Group substantial damage such as   acts in violation of laws and regulations, the Directors (excluding Directors serving on the Audit and Supervisory Committee), Executive Officers, employees and others of the Company shall immediately report the matter to the Audit and Supervisory Committee.
(2) The Internal Audit Department and the Risk Management Committee shall regularly report internal audit results and the status of other activities in Our Group to the Audit and Supervisory Committee.
(3) The department in charge of compliance shall regularly report the status of whistleblowing in Our Group to the Audit and Supervisory Committee.
(4) It is prohibited to treat unjustly of the reporter who reported to the Audit and Supervisory Committee, and the Company shall ensure that this matter would be passed down to all the executives and employees of the group.

8. Matters concerning procedures for advance payment or reimbursement of expenses incurred in the course of performance of duties by Directors serving on the Audit and Supervisory Committee and policies related to processing expenses or liabilities arising from performance of duties by Directors serving on the Audit and Supervisory Committee
The Company establishes enough budget for Directors serving on the Audit and Supervisory Committee each year to fulfill the performance of their duties.

9. Other systems to ensure that the Audit and Supervisory Committee’s audit is conducted effectively
 (1) The Representative Director and the Audit and Supervisory Committee shall hold a meeting on a regular basis to exchange opinions in order to communicate with each other.
(2) The Representative Director shall prepare an environment so that the Audit and Supervisory Committee is able to cooperate with external experts such as lawyers and certified public accountants in the course of its duties whenever it deems it necessary.
(3) The Audit and Supervisory Committee shall regularly provide opportunities for the exchange of opinions with the Internal Audit Department and accounting auditors.

10. Supplementary Provisions
The policy is enacted and enforced effective August 1, 2017.
The policy is revised and enforced effective January 1, 2018.

Corporate Governance Basic Policy

Based on our mission of “Delivering happy, refreshing moments to the everyday life of our consumers, customers, and communities”, we will improve soundness, transparency, and efficiency of our business management to make decisions that are strong against changes in a speedy manner by considering the viewpoints of all stakeholders such as the consumers, customers, regional communities, shareholders, and employees, etc., in order to realize improvement in mid- to long-term corporate values.
 This Policy stipulates the basic concept for us to realize corporate governance.

1.Relationship with the shareholders
(1) Ensuring the rights for the shareholders
① Based on the importance of the rights for the shareholders, we will make an effort to ensure appropriate correspondences so that the rights for all shareholders will be ensured.
(2) Interaction with the shareholders
① We acknowledge that shareholders’ meeting is an opportunity for holding constructive interactions with the shareholders, and will make an effort to develop the environment that is appropriate for all shareholders to execute their rights, and to provide adequate and easy-to-understand information. Additionally, in case a certain number of dissentient vote is made for any of the agenda proposed by the company at the shareholders’ meeting, we will implement cause analysis for the reason why there were so many dissentient votes, and will ensure to execute our accountability in order to let the shareholders understand our ideas through holding interactions with the shareholders.
② We will make an effort to let our Directors and Group Executive Officers to send out information on a regular basis so that we can promote understanding of the shareholders towards ourselves and to lead such understanding onto sustainable success and improvement in mid- to long-term corporate value via holding interactions with the shareholders, and will also make an effort to ensure information management and prevention in leakage of insider information.
(3) Capital policy
① We will implement the capital policy that will enable reinforcement in the financial structure aiming for improvement in corporate value, and enable active redistribution of profits to the investors and shareholders.
② Our basic policy is not to retain shares for political purposes. However, there may some cases where we obtain and retain shares for the purpose of creating business opportunities and of establishing, maintaining, and reinforcing the relationship with our partner companies and with the regional communities.
 Please be reminded that regarding the major shares retained for political purposes, efforts will be made to ensure evaluation and reporting regarding their holding cost and investment return in an appropriate manner.

2.Relationship with stakeholders other than the shareholders
(1) We will gain trust from various stakeholders such as the consumers, customers, regional communities, and employees, etc. by clarifying the significance or our existence, and by conducting the activities which provide values to each stakeholder, and therefore work upon improving our corporate value.
 ① We will pursue the satisfaction of our consumers’ and our customers’ by acting based on the viewpoints of our consumers’ and customers’ to provide products and services of better quality.
 ② We will aim to execute our social responsibilities and to contribute for rich and sustainable society as a corporate citizen, and will ensure preventive measures for environmental risks by taking care for environmental issues in various scenes among out business activities.
 ③ We will make an effort to establish the workplace environment where each individual employee is respected, where various senses of value and lifestyles are accepted, and where the possibilities and capabilities for each individual can be exercised to the highest extent including female employees taking on active roles.

3.Information disclosure and ensuring of transparency
(1) Appropriate information disclosure
① We will ensure appropriate disclosure of information regarding the financial status, financial data such as business management performances, and non-financial information such as those information regarding the management strategy, management issues, and risks and governance, etc. in accordance with the law, and will also work upon proactively providing information other than those required to be disclosed by the law.
② Based on the understanding that the information disclosed / provided will be the basis for holding constructive interactions with the shareholders, we will make an effort to provide accurate and easy-to-understand explanations.
 (2) Ensuring transparency
  ① We bear in mind that external accounting auditors hold an important responsibility for the shareholders and investors, and will implement appropriate correspondences in order to ensure adequate auditing.

4.Corporate governance structure
(1) The basic concept of the corporate governance structure
We will design optimum organizations in order to establish a structure which enables improvement in management soundness, transparency and efficiency, and therefore improve corporate value and shareholders’ value in the medium to long term.

5.Group management and decision making
(1) The basic concept of group management
We will ensure business management for the entire group as a one team, in a manner as if the entire group is a single company.
(2) The basic concept regarding the distribution and delegation of decision making authority
In order to ensure appropriate and smooth group business operations, decision making authority will be appropriately distributed and delegated to the company resolution organization and those members of management positions.
Additionally, in order to be able to promptly respond to the needs of the consumers’ and customers’ and to the changes in the market, we will develop a structure where the organizations closely related to the gemba (actual work site) can make decisions in a prompt and simple manner.
(3) Basic rules regarding the authorities and responsibilities
Clear scope of jobs and the authorities required for executing such jobs will be provided to each resolution organization and person with management positions. The resolution organizations and persons with management positions will be responsible for the results caused by having executed or not executed such authorities.

6.Supplementary provisions
This Policy shall come into force from January 1, 2018.

Disclosure Policy

We disclose information in a timely and appropriate manner with the aim of being properly understood and trusted by stakeholders.
Accordingly, we disclose information based on the Disclosure Policy described below as a part of a healthy and transparent corporate communications and disclosure approach.

1.Disclosure Principles
Coca-Cola Bottlers Japan Holdings Group (hereafter “Our Group”) discloses information in a timely and appropriate manner under the principles of transparency, fairness and sustainability with the aim of gaining trust from society so that domestic and overseas stakeholders, including shareholders and investors, can properly understand and evaluate Our Group.

Our Group disclose information according to the Companies Act, the Financial Instruments and Exchange Act, and other laws inside and outside Japan, as well as rules on the timely disclosure of corporate information stipulated in the Securities Listing Regulations of the listed exchange (hereafter Timely Disclosure Rules) and other rules. Our Group proactively provide information deemed relevant for investment decisions and understanding of Our Group even when the information is not subject to the Timely Disclosure Rules.

2.Disclosure Method
Information subject to the Timely Disclosure Rules is promptly published on the corporate website following disclosure via the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange.

Regarding information that is not subject to the Timely Disclosure Rules, Our Group strive to ensure that stakeholders have access to relevant information by posting materials on the corporate website, webcasting company earnings presentations, etc. when the information is deemed important for making investment decisions and understanding Our Group.

3.Handling of Earnings Forecasts and Future Information
 Any forward-looking statements, including plans, performance forecasts and strategies, are based on the assumptions and judgment of the management of Our Group in view of data and information available as of the date the material is released. Therefore, these forecasts may differ materially from actual performance due to various risks and uncertain factors. These risks and uncertain factors are included in company earnings materials in the Forward-looking Statements notice.

4.Handling of Insider Information (Designation of Quiet Period)
From the day after the quarterly settlement day to the announcement of the financial results, Our Group enter into a Quiet Period to refrain from making comments or responding to questions on financial results of the most recent settlement period and/or performance forecasts in order to prevent inappropriate disclosure of financial information and to maintain impartiality. However, Our Group may respond to questions during the Quiet Period if they are under the scope of information previously disclosed or otherwise publicly available.
Our Group endeavor to disclose information in a timely and appropriate manner in accordance with the Timely Disclosure Rules when there is any new information that is subject to these rules or when there is a material difference in expectations versus previously disclosed earnings forecasts.

5.Supplementary provisions
The policy is enacted and enforced effective January 1, 2018.

Anti-Bribery Policy

We hereby define this Policy to allow each one of us to act rightfully in compliance with laws, regulations, and social conscience in the course of interactions with government officials, etc., thereby aiming to become an excellent company with dignity.

1.Policy Summary
The nature of the business of Coca-Cola Bottlers Japan Group requires that we interact with various government officials, etc (as defined later). The laws and ordinances, CCBJI Group Code of Business Conduct & Ethics, and this Policy establish certain limits on the interactions with government officials, etc., particular where we might be providing something of value to a government official, etc.
This policy is intended to provide our employees with a level of awareness about laws and regulations associated with anti-bribery in order to avoid inadvertent violations as well as to recognize potential issues in time for them to be addressed appropriately. A violation of laws and regulations associated with anti-bribery can lead to severe administrative and criminal penalties; therefore it is vital that we not only understand and appreciate the importance of this Policy, but comply with it in our daily work.
Under this policy, the offering or acceptance of corrupt payment and other advantages between private (non-government) persons and entities shall constitute commercial bribery and be prohibited.

2. Policy Applies To/ Eligibility
This Policy applies to all employees of Coca-Cola Bottlers Japan Group (hereinafter referred to as “the Company”), including officers.

3.Policy Background
The Company must carry on its business with integrity based on the Code of Business Conduct & Ethics. This means avoiding corruption of all kinds, including bribery of government officials, etc.
The Company has employees from many countries and conducts business activities globally such as procurement from overseas; thus, it is important to comply with laws and regulations associated with anti-bribery in the countries and areas where our business partners locate in addition to those in Japan.
In addition, the Company has incorporated a prohibition against bribery into our Code of Business Conduct & Ethics, and this Policy provides explanation on the prevention of improper payments and permissible payments under all laws and regulations associated to anti-bribery that we must comply with (the criminal law, Unfair Competition Prevention Act, National Public Service Ethics Act , the Companies Act, U.S. Foreign Corrupt Practices Act (hereinafter referred to as “FCPA”), and the U.K. Bribery Act (hereinafter referred to as “UKBA”) and, China Unfair Competition Prevention Act (hereinafter referred to as “CUCPA”), etc. These laws and ordinances will be collectively referred to as “Applicable Corruption Laws” in this Policy.
When Applicable Corruption Laws are violated, in many cases, the person violated the laws will be sentenced or fined regardless of his/her nationality. Moreover, it is possible that the Company is fined also, which creates massive damage to the trust and reputation of the Company as well as to the Coca-Cola business.

4.Definition

For the purposes of this Policy, the term “Government Official” is broadly defined to include:
(1)Any officer or employee of any government entity, department, or agency
(2)Any employee of a national or public-owned business, school, hospital, or other entity
(3)Any political party, officer, or employee thereof
(4)Any politician or candidate for political office
(5)Any employee or official of a public international organization, department, or agency thereof (e.g., the United Nations, Olympic Organizing Committee, FIFA Committee, and World Bank)
(6)Any person acting in an official capacity on behalf of a government entity
(7)Deemed public servants (officers or employee of those entities (public corporation, institution, fund, incorporated administrative agency, and promotion association) deemed to be public servants by the laws and regulations *)

*If any concern arises on how to correspond with officers and employees of an organization, it is required to refer to the purpose of its foundation and regulations concerning duties and penalties.

(8)The term “Government Official” in this Policy also includes “Foreign Public Official” which is defined by the Unfair Competition Prevention Act as follows:
i.Any person who engages in public services for a national or local foreign government
ii.Any person who engages in services for an agency affiliated with a foreign national government
iii.Any person who engages in services for a foreign public enterprise
iv.Any person who engages in public services for an International Organization
v.Any person who exercises a public function on behalf of a foreign national government, etc. as delegated

5. Prohibited Payment on Applicable Corruption Laws
Applicable Corruption Laws prohibit companies and their employees and representatives from giving, promising, offering, or authorizing payment of anything of value to any government official, etc. in order to obtain or keep business or to secure some other improper advantage. In essence, these laws prohibit the giving of anything of value to influence actions of a government official, etc. Prohibited payments include, but are not limited to, those aim to:
(1)Induce the recipient to award a contract to the Company;
(2)Obtain advantageous tax or customs treatment that would not otherwise be available to the Company; or
(3)Circumvent or cause non-enforcement of laws or regulations applicable to the Company.

6. Prohibition on Bribery

The prohibition on bribery applied to the giving of anything of value, not only money including providing business opportunities, favorable contracts, stock options, gifts, and entertainment. Such acts are barred even if:

(1)The benefit is for someone other than the party making the payment.
(2)The business sought is not with the government organizations.
(3)The payment does not in fact influence the government official’s conduct.
(4)The government official initially suggested the payment.

7. Prohibition on Commercial Bribery

The UKBA and CUCPA specifically prohibit the offering or acceptance of corrupt payments and other advantages between private (non-government) persons and entities. Such conduct constitutes commercial bribery, Such conduct is prohibited by our Code of Business Conduct & Ethics.
8. Facilitating Payments
Facilitating (or expediting) payments (i.e. gratuity) (hereinafter referred to as “Facilitating payment”) also are prohibited under this Policy. Facilitating Payments for Facilitation are small payments paid to lower-grade public officers in order to expedite or facilitate non-discretionary actions or services or typical government procedures.
As the examples from overseas, obtaining an ordinary license or business permit, processing government papers such as visas, providing police protection, providing telephone, power, or water service, or loading or unloading of cargo falls under this category.
Especially when you encounter a situation that you believe may require a facilitating payment to government official, etc. in overseas, contact Legal Compliance Department for consultation.

9. Prior Approval from Legal Compliance Department
(1) Duty of prior approval
Our Code of Business Conduct and Ethics and this Policy require employees to obtain approval from Legal Compliance Department before providing anything of value to a government official, etc.
(2) Exception
There is an exception to this general rule:
Payments are permissible without prior approval when an employee’s safety is at issue, as for example when a payment must be made immediately to ensure safe passage out of a particularly dangerous geography. Employees should make whatever payment is necessary to protect their personal safety, and then, as reasonable, report the nature of the incident and related payment to Legal Compliance Department.
(3) Prior Consultation

Anti-bribery matters are not always clear and must often be addressed on a case-by-case basis.
In all situations where there is a question, employees should consult Legal Compliance Department.

10. Limited Exceptions
(1) Gifts, Meals, and Entertainment
It is not always easy to identify whether providing gifts, meals, and entertainment (or other hospitality) would be considered a corrupt act under Applicable Corruption Laws.
It may be permissible under such laws to provide modest gifts or a meal or other entertainment to a government official as a social amenity. Generally, gifts, meals, and entertainment are permissible, provided that:
i.There is no expectation that the gift, meal, or entertainment is given in exchange for any return favor or business advantage from the government organizations;
ii. The gift, meal, or entertainment is infrequent, reasonable, and proportionate in amount under the circumstances; and
iii. An approval is obtained from Legal Compliance Department beforehand.

When deciding whether a gift is appropriate, employees must take into account any past or future administrative matters that are within the recipient’s realm of influence. The timing and context surrounding such gifting must be weighed in order to assess whether any particular gifting could objectively be perceived to be a bribe.
Before providing any gift, meal, or entertainment to a government official, always seek approval from Legal Compliance Department.
(2) Donations
It is sometimes permissible under Applicable Corruption Laws to make donations directly to government organizations (rather than to an individual government official) as part of a charitable effort or to promote goodwill through such actions as providing products to a government organization-sponsored celebration. Donations made to government organizations are permissible, provided that:
i.There is no expectation that the donation is given in exchange for any return favor or business advantage from the government organization;
ii.The donation is not made directly to an individual government official, and there is no indication that the donation will be redirected to an individual official’s personal use; and
iii.The donation is infrequent and reasonable in amount under the circumstances.
Donations to private charities should not be made in the name of a government official, as a donation to an official’s favorite charity could be viewed as a bribe.

In addition, the Company specifies those with approval authority over donations in the Regulations of Authority and Responsibility stipulated separately from this Policy. All donations made on behalf of the Company must follow the process specified in the Regulations of Authority and Responsibility. For more information, please refer to the Regulations of Authority and Responsibility.

(3) Political Contribution
The Company specifies those with approval authority over political contributions in the Regulations of Authority and Responsibility stipulated separately from this Policy. All political contributions made on behalf of the Company must follow the process specified in the Regulations of Authority and Responsibility. For more information, please refer to the Regulations of Authority and Responsibility.
(4) Hiring or Engaging Government Officials
The Company prohibits hiring of government officials as general rule.

11. Third Parties
(1) Prohibition of Unlawful Payment via Third Parties
Applicable Corruption Laws with which we must comply prohibit corrupt payments made directly by Company employees or indirectly through an agent or other intermediary such as a consultant acting for or on behalf of the Company (hereinafter referred to as “Third Party).
It is unlawful to make a payment of anything of value to any person, knowing that all or any portion of the payment will be offered, given, or promised to a government official or any other person for a corrupt purpose. The term “knowing” includes conscious disregard, deliberate ignorance, and willful blindness. In other words, the Company and individual employees may violate the FCPA if we have “reason to know” or “should have known” that an agent will bribe a government official, etc.

A company can be held criminally liable for bribes paid on its behalf by a third party in some country or area even if the company had no knowledge of the bribe.

(2) Careful Selection of Third Parties

Accordingly, the most important stem the Company can take to protect itself from liability for improper payments made by Third Parties is to choose carefully its business partners, including agents and consultants.

(3) Cases that may pose risks
Moreover, these “red flags” warrant further investigation when selecting or working with a Third Party. The following are examples of red flags:
i.The transaction involves a country known for corrupt payments.
ii.The third party has a close family, personal or professional relationship to a government official, etc. or relative of an official, etc.
iii.The third party objects to anti-corruption representations in Company agreements.
iv.The third party requests unusual contract terms or payment arrangements (e.g., payment in cash, payment in foreign currency, or payment in a third country).
v.Third party is suggested by a government official, etc (particularly one with discretionary authority over the business at issue).
vi.The third party’s commission or fee exceeds fair and reasonable compensation for the work to be performed.
In all cases, whether or not any of these red flags are present, consult and seek approval from Legal Compliance Department before entering into any arrangement with a third party who will have a contact with a government official, etc. on behalf of the Company.
(4) Due Diligence

No relationship should be developed with a third party who will have substantive interaction with government officials, etc. on behalf of the Company without an inquiry into the third party’s background, qualification and reputation.
When selecting a third party who will have substantive interaction with government officials, etc. on the Company’s behalf, necessary information to thoroughly assess the background and reputation of the third party shall be obtained and confirm that:
i.The third party is not a government official or a company in which a government official has an interest, and
ii.The third party will become familiar with the Company’s Code of Business Conduct & Ethics as well as Anti-Bribery Policy and certify that it will not engage in any improper practices that could expose the Company to liability or are otherwise inconsistent with Company business practices.

(5)Conclusion of Contract
All third party relationships that may involve contact with government officials, etc. must be identified in written contract including articles concerning compliance with all Applicable corruption Laws. When entering into a relation with a third party with interaction with government officials, etc., a written contract must be concluded including articles concerning compliance with Applicable corruption Laws. When creating a contract, please consult with Legal HQ.
Once an agent or consultant has been retained by the Company, the individual’s activities and expenses must be monitored to ensure compliance with the Applicable Corruption Laws and Company Policy.

12. Recordkeeping
To keep record accurately and properly, all Company employees must:
(1)Follow the Company’s Code of Business Conduct & Ethics, Company procedures, and Generally Accepted Accounting Principles;
(2)Accurately record all transactions, even when the transaction might violate Applicable Corruption Laws;
(3)Never agree to request for false invoices or for payment of expenses that are unusual, excessive, inadequately described, or otherwise raise questions under regulations, laws, and rules; and
(4)Never make any payments to anonymous (i.e., “numbered”) accounts that are in the name of neither the payee nor an entity known to be controlled by the payee.

13. Auditing

Audit Section will conduct periodic audit of relevant Company operating units to ensure continued compliance to all Applicable Corruption Laws and this Policy.

14. Ethics & Compliance Reporting Hotline

Any observation of conducts that violate this Policy, please report it to Legal Compliance Department or call or send an e-mail to Ethics & Compliance Reporting Hotline. Suspected violations will be reviewed and investigated as appropriate and may lead to disciplinary action. Any retaliation for good faith reports will be violation of the Code of Business Conduct & Ethics. The Company prohibits any employees from taking measures that cause negative influence on the employment of the employee based on the fact that he/she made a good faith reports for his/her concern or cooperated with the investigation.

15.Supplementary Provisions

The policy is enacted and enforced effective April 1, 2017.
The policy is revised and enforced effective January 1, 2018.
Basic Policy for Procurement

We are procuring various goods and services so as to deliver products that are safe and reassuring for our customers. As an excellent company with dignity, we are committed to engaging in procurement activities in accordance with the following policies.

1.Our declaration for procurement activities
We are committed to comply with all applicable laws and engage in appropriate procurement activities in accordance with these policies, as well as the Code of Business Conduct and Ethics, regulations, handbook, and other rules of Coca-Cola Bottlers Japan group.

2.Fair and transparent trade practices
(1)We uphold fair, transparent, and free competition and will not engage in any unfair trade practices in our procurement such as those causing unreasonable disadvantage to our suppliers.
(2)We maintain equal and healthy relationships with our suppliers. In no event will we have any inappropriate relationships with our suppliers where we accept or demand benefits such as accepting gratuities or receiving entertainments or gifts that are beyond socially acceptable norms.
(3)We conduct appropriate education and guidance to prevent our executives and employees from engaging in unfair trade practices or having inappropriate relationships with suppliers.

3.Economic rationality
We select suppliers based on appropriate standards and through comprehensive evaluations with respect to product quality, price, delivery date, ability of maintaining stable supply, systems for complying with laws, reliability as a corporate entity, and other factors.

4.Appropriate control of information
We fully recognize the importance of confidential information and personal information obtained through procurement activities, and use and control such information in an appropriate manner in accordance with its category.

5.Environment
We engage in procurement activities with due consideration given to the global and regional environment.

6.Mutual prosperity
Our business cannot sustain its activities without cooperation and support from suppliers. Bearing in mind that our suppliers are our partners for growth, we are committed to furthering mutual prosperity and sustainability for growth.

7. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.

Basic Policy for Procurement

We are procuring various goods and services so as to deliver products that are safe and reassuring for our customers. As an excellent company with dignity, we are committed to engaging in procurement activities in accordance with the following policies.

We are procuring various goods and services so as to deliver products that are safe and reassuring for our customers. As an excellent company with dignity, we are committed to engaging in procurement activities in accordance with the following policies.

1.Our declaration for procurement activities
We are committed to comply with all applicable laws and engage in appropriate procurement activities in accordance with these policies, as well as the Code of Business Conduct and Ethics, regulations, handbook, and other rules of Coca-Cola Bottlers Japan group.

2.Fair and transparent trade practices
(1)We uphold fair, transparent, and free competition and will not engage in any unfair trade practices in our procurement such as those causing unreasonable disadvantage to our suppliers.
(2)We maintain equal and healthy relationships with our suppliers. In no event will we have any inappropriate relationships with our suppliers where we accept or demand benefits such as accepting gratuities or receiving entertainments or gifts that are beyond socially acceptable norms.
(3)We conduct appropriate education and guidance to prevent our executives and employees from engaging in unfair trade practices or having inappropriate relationships with suppliers.

3.Economic rationality
We select suppliers based on appropriate standards and through comprehensive evaluations with respect to product quality, price, delivery date, ability of maintaining stable supply, systems for complying with laws, reliability as a corporate entity, and other factors.

4.Appropriate control of information
We fully recognize the importance of confidential information and personal information obtained through procurement activities, and use and control such information in an appropriate manner in accordance with its category.

5.Environment
We engage in procurement activities with due consideration given to the global and regional environment.

6.Mutual prosperity
Our business cannot sustain its activities without cooperation and support from suppliers. Bearing in mind that our suppliers are our partners for growth, we are committed to furthering mutual prosperity and sustainability for growth.

7. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.

Basic Policy for Suppliers

We aim to become an excellent company with dignity and therefore require all our employees to be ethical and in compliance with applicable laws in everything they do. Cooperation by all suppliers is also indispensable to achieve our aim, which is providing great support in our business.
For this reason, we have established these Basic Policies for Suppliers as the minimum requirement that we expect all of our suppliers to comply with.
These policies apply to all suppliers that do business with Coca-Cola Bottlers Japan Inc. (hereinafter referred to as the "Company"), and we require all to comply with all of the following policies.

1.Compliance with laws
Suppliers should comply with all applicable national and local laws, rules, regulations, and requirements in their manufacturing and distribution of the Company's products and supplies, as well as in their provision of services.

2. Freedom of association and the right to collective bargaining
Suppliers should respect the right of all their employees to decide at their will whether or not to join a labor union or to organize one in compliance with all applicable laws, free from fear of retaliation, threatening, or harassment. Constructive dialogues and negotiations in good faith should be conducted with representatives of a legitimate labor union chosen by the employees at their free will.

3. No child labor
Suppliers should comply with the minimum years of age for work as prescribed by applicable laws and regulations.

4. No forced labor or abusive treatment of workers
Suppliers should prohibit any physical abuse to its employees and all forms of forced labor and human trafficking.

5. Elimination of discrimination
Suppliers should eliminate discrimination both at the time of and during employment, and maintain a workplace free from physical or verbal harassment. Every effort should be made to ensure equal opportunity in the workplace and fairness in treatment.

6. Working hours and compensation
Suppliers should operate their business in compliance with all applicable laws governing wages, working hours, overtime hours, and welfare and benefits.

7. Providing safe and healthy working environment
Suppliers should provide a safe and healthy workplace where all people concerned feel secure at work. The workplace should be maintained to achieve high productivity where all risks of accidents, injuries, and any other aspects harmful for health are minimized.

8. Protection of environment
Suppliers should operate their business in such a way as to preserve and protect the environment. Comply with all applicable national and local environmental laws.

9. Doing business with integrity
Suppliers should comply with all applicable national and local laws, and should not do any acts of wrongdoing.
  (1) No acts of inducing conflict of interests
Exercise caution not to allow its employees to enter into any relationships with an employee of the Company, which relationship may induce conflict of interests.
(2) Bribery
Do not provide or accept any gifts or entertainment in any business relationships, aiming to gain inappropriate benefits.
(3) Accurate records
Maintain accurate records of all matters in all transactions, ensure appropriate processing of accounts or other matters, and submit accurate invoices to the Company.
(4) Protection of information
Keep in confidence all confidential information exchanged in the business relationship with the Company. Ensure appropriate control and protection of personal information.
(5) Fair trade practices
Do not engage in any acts of impairing fair, transparent, and free trade practices.
(6) Protection of intellectual property rights
Respect all intellectual property rights, and do not infringe those owned by third parties.
(7) Quality of products
All products should satisfy the quality requirements agreed with the Company by way of contracts or otherwise, so as to provide safe products and services.

10. Handling of complaints and providing remedies
Suppliers should provide its employees with a mechanism that enables its employees to request for consultation or to make complaints without fear of retaliation, and ensures appropriate and timely countermeasures against any concerns raised by its employees.

11. Demonstrating compliance
Suppliers should be capable of, at the request of the Company, demonstrating its compliance with these Basic Policies for Suppliers.

12. Miscellaneous provisions
(1) The Company, THE COCA-COLA COMPANY, or COCA-COLA (JAPAN) COMPANY, LIMITED (hereinafter collectively referred to the "Company, etc."), or a third party designated by the Company, etc. may conduct audits to confirm the suppliers' compliance with these Basic Policies for Suppliers.
(2) The Company will have the right to require corrective actions to be taken by any supplier which violates these Basic Policies for Suppliers.
(3) The Company reserves the right to terminate all agreements and contracts with a supplier who fails to demonstrate its compliance with these Basic Policies for Suppliers.
(4) There may be a case where a separate agreement or contract with a supplier contains certain similar provision that is in greater detail than the provision in these policies. In such case, the provision of that agreement or contract will prevail.
(5) If the eight core conventions of the International Labor Organization (ILO) set higher labor standards than those set by local governments, the Suppliers should satisfy the standards of ILO.
(6) These Basic Policies for Suppliers are subject to change without notice in response to future amendments of applicable laws or regulations.

13. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.

Tax Basic Policy

All directors and employees of the company act with a strong sense of ethics, whether in business or personal life, as well as comply with laws and regulations, social norms, and company regulations. We at the company also recognize that properly fulfilling tax obligations is one of the fundamental and important social responsibilities of a company, and in conducting tax practice, all its group companies properly assess and pay taxes, complying with relevant laws and regulations and conforming to the basic principles, policies, and code of business conduct & ethics specified by the company, based on the basic guidelines below:

1.We pay taxes properly in accordance with tax-related laws and regulations.

2.We conduct appropriate tax management, always ensuring that there are no omissions or delays with regard to tax-related accounting and other associated actions.

3.We conduct efficient and continuous tax management in light of maximizing shareholders' value. We do not avoid taxes through interpretation/application that deviates from the purpose of relevant laws and regulations.

4.We maintain good relations with tax authorities through smooth communication with them and sincerely respond in good faith to ensure transparency and credibility in relation to tax practice.