Anti-corruption policy

Kyo Electric 2023 Anti-Corruption Policy

Kyo Electric has implemented a series of regulatory compliance policies that develop ethical and good governance principles and values.

Its commitment to the fight against corruption means that the development of its activities is carried out under the principles of honesty, integrity, honesty and responsibility.

The scope of application of this Policy is of a minimum nature and must be known and applied by all Kyoto Electric employees. Its objective is to regulate those behaviors that affect the acceptance and offering of gifts and the making of invitations to influence the decisions of third parties.

This policy is mandatory for all directors, officers and employees of Kyo Electric.

Gifts and invitations prohibitions and acceptable practices

It is forbidden to offer, promise, pay, give or authorize the giving of gifts and invitations to any natural or legal person in order to unduly influence a decision, to obtain or maintain a business or any other advantage.

Only acceptable practices shall be considered:

• Those that are in accordance with laws and regulations.
• Delivered or accepted without expectation of reciprocity.
• And in any case of socially acceptable value and customs, occasional and not excessive.

In the case of trade fairs, presentations and commercial events

• Expenses associated with the presentation of products at trade fairs and commercial events may be defrayed to customers.
• Such invitations may also be accepted from suppliers and other business partners provided that they are in connection with the purpose of attending such presentations and events.

Control interno y sanciones

All gifts and entertainment, both given and received, must be reported to Kyoto Electric’s management in writing for internal control.

It is the responsibility of directors, officers and employees to strictly comply with this policy.

Supervisory mechanisms will be implemented to verify its application and if there is evidence of possible non-compliance, the appropriate investigation will be carried out.

In the event that non-compliance is confirmed, it will be reported to Management and Human Resources, assessing its seriousness and determining the sanction to be imposed.

Kyo Electric will encourage any employee or collaborator to communicate any suspicion or evidence to Management.