To promote appropriate and sound business activities based on our corporate identity, we, Admatechs Co., Ltd., have established the "Basic Bribery Prevention Policy" described below and shall act in full accordance with this Policy. We ask our business partners to understand our implementation of the Basic Bribery Prevention Policy and appreciate your kind cooperation.

1Prohibition on Giving Bribes

We shall never seek to earn profits which could be obtained only by bribery or other wrongful means.

1 ) To Public Employees (any public employees or the equivalent)

We shall not offer, promise, or propose any monetary or other profits or benefits (hereinafter referred to as the Monetary Consideration*2) directly or indirectly to any Public Employees, regardless of whether in Japan or overseas, with intent to influence the execution of their duties in order to obtain or retain any business or any business advantage for us*1, and shall not approve any of the above acts.

※Facilitation Payment
In certain countries or regions, small-sum payments not governed by any applicable laws (“Facilitation Payment”) may be claimed by Public Employees for procedures such as customs clearance, checkpoints, application for the issuance or extension of entry visa or stay visa, and the installation of water and sewerage or phone lines. Such Facilitation Payment is deemed as Bribery of Public Employees, and we shall never make any Facilitation Payment.

2 ) To Non-Public Employees

We shall not offer, promise, or propose Monetary Consideration directly or indirectly to any third party, regardless of whether in Japan or overseas, in order to obtain or retain any business or any business advantage for us,

Ⅰ )with intent to make them conduct unfair/illegal performance of duties,
Ⅱ )in consideration of their unfair/illegal performance of duties, or
Ⅲ )recognizing that the acceptance of Monetary Consideration by any third party constitutes an unfair/illegal performance of duties.

2Prohibition on Accepting Bribes

In our business activities regardless of whether in Japan or overseas, we shall not demand, promise to accept, or receive Monetary Consideration that is connected with unfair/illegal performance of duties for a third party*3.

3Prohibition of Fraudulent Accounting

In our business activities, we shall not engage in any off-balance-sheet transactions, fictitious transactions, or any other false or misleading transactions, and shall always make and retain accounting records (such as ledger sheets and account ledgers) which reflect all of the transactions of business and the disposal of assets in a fair and accurate manner.

4Thorough Understanding and Cooperation for Investigations concerning Prohibitions on Bribery

We shall ensure that our executive officers and employees are all well informed of the purpose and content of this Policy and the laws and regulations governing the prohibitions on bribery by offering training opportunities. If we are involved in or suspected of being related to any bribery or fraudulent accounting, we will provide total cooperation for investigations to be conducted by the relevant authorities.

September 4, 2015

President Susumu Abe

*1 ) "To obtain or retain any business or any business advantage" includes the following:
→ Simplification or facilitation of procedures, procurement of approval and/or licenses,
acquisition of business transactions, and acquisition of confidential information.

*2 ) "Monetary Consideration" includes the following:
→ Money, cash vouchers, gift-giving, entertaining, donations, and rewards.

*3 ) "Unfair/illegal performance of duties for a third party" includes the following:
→ Offer of business transactions and offer of confidential information

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