Anti-Bribery & Anti-Corruption Policy

Policy Statement

mtc is committed to conducting its business ethically and in full compliance with all applicable anti-bribery and anti-corruption laws in Japan, including the Unfair Competition Prevention Act (不正競争防止法), which prohibits the bribery of foreign public officials, and other relevant domestic regulations. We do not tolerate bribery or corruption in any form, whether in dealings with public officials or private sector partners.

Prohibited Conduct

Employees, contractors, and third parties acting on behalf of mtc must not offer, give, request, or accept bribes, kickbacks, facilitation payments, or anything of value intended to improperly influence a decision, secure an unfair advantage, or obtain or retain business.

This applies to both government officials and private individuals in Japan or abroad. Any such activity is strictly prohibited regardless of local customs or business practices.

Gifts and Hospitality

While reasonable and transparent business entertainment or courtesy gifts may be acceptable in some contexts, they must never be used to improperly influence business decisions. All gifts and hospitality must be modest, lawful, and approved according to our internal guidelines.

Third Parties and Business Partners

mtc expects all suppliers, agents, and partners to act with integrity and comply with anti-bribery laws. We perform reasonable due diligence on third parties where appropriate and will disengage from any relationship where bribery or corruption is suspected or confirmed.

Reporting and Whistleblowing

Employees are encouraged to report any suspected bribery or unethical conduct without fear of retaliation. Reports can be made confidentially to management or via designated reporting channels. All concerns will be investigated promptly and fairly.

Compliance and Disciplinary Action

All employees must comply with this policy and complete any related training. Breaches of this policy may result in disciplinary action, up to and including termination of employment or contract, and may also lead to legal consequences under Japanese law.