Anti-Bribery Policy

FANUC acts in compliance with applicable domestic and international laws and regulations concerning the prevention of offering bribes, etc. FANUC hereby also sets forth this Anti-Bribery Policy (this “Policy”) and FANUC officers and employees shall act in compliance herewith.

1. Prohibiting the Offering of Bribes, etc.

(1) Regardless of whether or not FANUC bears the expenses, FANUC officers and employees will not directly and indirectly engage in any provision of bribes, offer or promise to engage in any provision of bribes, or otherwise engage in any acts relating to corruption (including making facilitation payments, i.e. payments of small amounts made to public officials in order to facilitate procedures for administrative services) to any national or foreign public officials and persons comparable thereto (i.e. officers and employees of a national government, local government, international organization, etc.; collectively, “Public Officials”). Moreover, FANUC officers and employees will not accept any entertainment, gifts or other benefits that go beyond sound business practices or social norms.

(2) FANUC officers and employees will not engage in any provision of entertainment, gifts, profits, and other benefits to business partners who are not Public Officials, or their officers and employees, etc., unless those actions are made in compliance with applicable domestic and international laws and regulations and within a scope that is appropriate in terms of social norms.

2. Preventing Other Corruption

In addition to not offering bribes, FANUC officers and employees will also not engage in any act relating to corruption which abuses their official authority or position for the benefit of an individual or organization, including embezzlement, breach of trust, obstruction of justice or money laundering.

3. Third Parties such as distributor, etc

If there is a risk of any of the acts specified in Articles 1 and 2 being carried out through any third party, such as a distributor, supplier, intermediary or consultant, no FANUC officer or employee will engage such third party.

4. Retaining Records

FANUC shall accurately record its accounting books based on the facts in order to ensure accountability for compliance with applicable laws and regulations concerning the prevention of offering bribes, etc, as well as compliance with this Policy.

5. Establishing a Reporting System

If any FANUC officer or employee is suspected of being in breach of this Policy, FANUC will make sure that information is promptly shared so that the issue will be handled in a timely manner.

6. Review and Improvement of This Policy

FANUC will review, revise and improve this Policy as necessary.

* This Policy applies to FANUC CORPORATION and its domestic and foreign subsidiaries.

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