Sustainability

Anti-Corruption and Corporate Ethics

Anti-Corruption and Corporate Ethics

In accordance with the "ZOZO Basic Policy on Anti-Corruption," we are committing to ethical and honest business practices while establishing a framework to prevent corruption. To reinforce these efforts, we conduct anti-corruption training for all employees, including part-time and temporary staff.

ZOZO Basic Policy on Anti-Corruption

Article 1 (Purpose)
The purpose of this Basic Policy is to promote anti-corruption efforts throughout ZOZO in the spirit of fair play. By clarifying the policies that all officers and employees of ZOZO (hereinafter referred to as the "Officers and Employees") should adhere to, in accordance with the ZOZO Group Code of Conduct, we aim to secure the trust of stakeholders and society in general.

Article 2 (Scope of application)
This Basic Policy applies to all Officers and Employees of ZOZO, regardless of the country or region in which they operate.

Article 3 (Compliance with laws and regulations related to anti-corruption)
Officers and Employees shall comply with all anti-corruption laws and regulations applicable in each country or region, this Basic Policy and internal rules including internal regulations (hereinafter collectively referred to as the "Related Rules, Etc.").

Article 4 (Prohibition of giving bribery)
1.Except as permitted by Related Rules, Etc., Officers and Employees shall not directly or indirectly provide money or other benefits, or make offers or promises thereof, to public servants, etc., and private sector customers, business partners, and other business operators (hereinafter referred to as the "Business Partners, Etc.") with corrupt intents.
2.Officers and Employees shall not direct bribery through third parties such as agents, consultants, distributors, subcontractors, etc., nor tolerate or condone such third parties giving bribery.

Article 5 (Prohibition of accepting bribery)
Officers and Employees shall not directly or indirectly receive, demand or promise to receive corrupt or unjustified benefits, with respect to their duties.

Article 6 (Thorough record-keeping and storage)
Officers and Employees shall comply with procedures concerning financial reporting, accurately record all transactions in accounting books, and properly store relevant materials.

Article 7 (Lawful entertainment, gifts, etc.)
1.ZOZO shall properly manage entertainment, gifts, donations, support and sponsorship with public servants, etc., and Business Partners, Etc. that are lawfully provided for legitimate business purposes, in accordance with the Related Rules, Etc.
2.ZOZO shall pay special attention to the entertainment or gifts to public officials.

Article 8 (Audit)
ZOZO shall appropriately operate a system for conducting self-inspections and internal audits according to the degree of risk, regarding the status of compliance with this Basic Policy and the internal rules established based on this Basic Policy.

Article 9 (Structure and response)
1.In order to ensure a structure for complying with this Basic Policy, ZOZO shall establish internal reporting desks to which the Officers and Employees can report general compliance issues, including anti-corruption.
2.In the event that any violation or potential violation of the Related Rules, Etc. is discovered,  ZOZO shall conduct a rigorous internal investigation and fully cooperate with any investigation by the relevant authorities, etc.
3.Officers and Employees who violate the Related Rules, Etc., may be subject to personal liability and will be subject to strict disciplinary actions in accordance with the internal regulations of the company or their employment/delegation contract.

Article 10 (Enforcement)
This Basic Policy shall be enforced from October 1, 2023.

*Basic Human Rights Policy approved by the Management Meeting on September 27, 2023

For Fair Trade

In order to comply with the Antimonopoly Act and the Subcontract Act, we conduct compliance training to raise awareness and raise awareness of the issue so as not to use unreasonable restraint of trade or unfair trade practices that are subject to regulation. In addition, we confirm whether we comply with the Subcontracting Act in the procedures for internal contract review and conclusion. We announced in the "Declaration of Partnership Building," declared by representatives of companies to build new partnerships by promoting collaboration and co-existence and co-prosperity among business partners in the supply chain and businesses that seek to create value.

Prohibition on Conflicts of Interest

The Company has established "Guideline to ensure the fairness of transactions with the parent company group" for transactions with major shareholders, etc. and operates in accordance with these rules. With respect to transactions with major shareholders, etc., the Company shall comply with laws and regulations, and shall not conduct such transactions on terms unjustly favorable or disadvantageous to the Group as compared to the same, the same kind of or similar transactions conducted with third parties, and shall reasonably determine such transactions by taking into account the terms of the contract and market price as in the case of transactions with other companies.

Anti-Corruption Initiatives

Internal audits, including those to prevent corruption, are conducted based on an annual plan, and efforts are being made to ensure the effectiveness of preventive measures. If we discover an act that may involve or be involved in a corrupt transaction, the Compliance Committee will conduct an internal investigation and punish the employee strictly by the Disciplinary Committee in accordance with the Work Rules.