SoftBank Anti-Bribery and
Corruption Policy

  1. Fundamental Philosophy

    Compliance at SoftBank means not only complying with laws and regulations but also meeting society's higher ethical expectations that include social norms and moral standards. We believe that it is important to ensure the social credibility of the Group through fair business practices.
    The SoftBank Code of Conduct, which sets out standards of conduct for all employees and officers of the Group to follow, also declares our “commitment to fair business practices” in which we maintain fair and mutually viable relationships with our business partners, as well as our “appropriate relationship with politics and government” in which we maintain appropriate relationships with politics and government without being involved in corruption or unethical behavior such as providing or receiving inappropriate gifts or entertainment. This Policy clarifies the Group's anti-bribery and corruption principles declared in the SoftBank Code of Conduct and applies to officers and employees of SoftBank Corp. and Group companies.

  2. Policy of SoftBank Corp.
    • -No bribery

      Engaging in bribery with government officials or civil servants is prohibited, whether in Japan or abroad.
      Bribery includes not only cash but anything that benefits the recipient (such as entertainment, gifts, political contributions, charitable donations, sponsorships, offers of employment, kickbacks, etc.), and so actions performed for the purpose of gaining unfair advantage are prohibited in any form.
      Facilitation payments (small payments to foreign government officials, etc. for the purpose of facilitating procedures related to non-discretionary and routine administrative services) are also prohibited.
      In countries or regions where the provision of benefits to officers and employees of private companies is regulated by laws and regulations, we will act appropriately so as not to violate such laws and regulations.

  3. System and Efforts to Prevent Bribery and Corruption
    • -Supervision by the Board of Directors

      The Board of Directors appoints the Chief Compliance Officer (CCO) as the person responsible, and oversees corporate ethics and corruption issues.

    • -Obtaining approval and keeping records

      Benefits such as entertainment or gifts will be provided only after following the required procedures based on the rules stipulated in regulations and obtaining approval of the CCO, and accurate records of all transactions will be kept.
      Records of entertainment expenses will also be regularly checked after the fact from the viewpoint of preventing corruption.

    • -Donations and sponsorships

      Donations and sponsorships will be provided in a manner such that no corruption is involved.

    • -Political contributions

      The Group maintains a politically neutral position and does not support any particular political party or politician in any way.
      We will make no political contributions for the purpose of promoting policies or positions that benefit Group companies.
      Political contributions are subject to approval by the Board of Directors (for unlisted Group companies, prior consultation with the CCO of SoftBank Corp. and approval by the Board of Directors of SoftBank Corp. is required), and any political contributions made will be publicized.

    • -Whistleblowing system

      A whistleblower hotline is established and operated to allow reporting of violations of laws and regulations, including bribery and corruption.
      Whistleblowers can report anonymously and will not be subject to adverse treatment due to making a report.

    • -Awareness and training of employees

      Employees will be made fully aware of this Policy on a regular basis and will be provided training to prevent bribery and corruption.

  4. Compliance with Laws and Regulations

    We comply with the anti-bribery laws of each country, including the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, and Japanese Unfair Competition Prevention Act.

  5. Hideyuki Sato
    Vice President & CCO, Compliance Office Head