Anti-Corruption Policy

Anti-Corruption Policy - Mokuhyou Shinbun Group - Japan | Web site: connectionjapan.com

1. What is anticorruption?
2. The Anti-Corruption Policies of the Mokuhyou Shinbun Group - Japan.
3. For who and how.
4. What are acts of corruption?
The. Right, but who are the public agents?
B. And what I can and can not do.
5. What can happen.
6. What if I find out?
1. What is anticorruption?

It is important to first conceptualize corruption.

In a broad sense, corruption can be understood as any improbable act that holds in itself a deviation from institutional goals by a private individual in relation to a public agent or state entity. In Brazil, corruption is defined as a crime by the Criminal Code, according to articles 317 and 333, subjecting to penalties the individuals that offer and the public agents that request, demand or accept, an undue advantage.

In addition, the Law of Administrative Improbity (Law No. 8429 / 92) lists a series of unlawful acts that violate the principles of administrative morality and that cause illicit enrichment of the public agent and that can subject the condemned to civil and administrative sanctions. In 2013, the National Congress approved Federal Law no. 12.846 / 13, known as the Anti-Corruption Law.

The great novelty of the law was the strict imposition of responsibility on legal entities that are involved in acts of corruption, called in the law of acts harmful to the public administration. Anti-corruption law requires proactiveto prevent acts of corruption. While the Criminal Code and the Administrative Improbability Act have reactive character, that is, they punish after the acts have happened (if discovered), the Anti-Corruption Law has a character preventive, requiring companies to have internal systems and policies that prevent the occurrence of these acts. Thus, anticorruption can be defined as a set of preventive measures of acts of corruption (acts harmful to the public administration) that can occur during the business activities.

2. The Anti-Corruption Policies of the Mokuhyou Shinbun Group - Japan.

Group Mokuhyou Shinbun Japan, has always guided its activities by seriousness and honesty, and its mission is to disseminate and defend the principles of democracy and free enterprise. Corruption, however, is one of the greatest obstacles to democracy since it channels the public resources necessary for the development of the social plan for individuals in an illicit and unjust way.

That is why the Mokuhyou Shinbun Japan Group, through its news media always gave visibility to corruption scandals and condemned the practice in a ferocious way in its editorials. Doing this in your journalistic activity is not everything. It is of the utmost importance that the corporate activity of the Mokuhyou Shinbun Group Japan itself bears the task of avoiding acts of corruption. Therefore, the Code of Ethics and Conduct and the Editorial Principles, Ethical and Quality Norms provide explicit predictions of behaviors to be avoided and adopted, with the aim of preventing acts harmful to public administration.

In addition, the Group has a specific procedure to supervise and monitor its internal regulations, complaints channels and specific procedures for determining and dealing with third parties. These standards and procedures form the normative basis for Mokuhyou Shinbun Group's anti-corruption policies in Japan.

However, in addition to the normative basis, it is necessary that the prevention of acts of corruption be instilled in the mentality of each collaborator of the Mokuhyou Shinbun Japan Group and its developers, in order to build a new culture in which even the most common acts of personal favors are not tolerated.

3. For who and how?

The anti-corruption policy of the Mokuhyou Shinbun Japan Group should be implemented by all employees of the Mokuhyou Shinbun Japan Group, without exception! This policy should also be followed by any third party related to the activities of the Mokuhyou Shinbun Japan Group, as those who act for their benefit. This includes service providers, commercial representatives and even journalistic sources, regarding the matters elaborated by the journalists of the Group Mokuhyou Shinbun Japan.

For this, it is necessary for everyone to know the Mokuhyou Shinbun Japan Code of Ethics and Conduct, the Editorial Principles and the Ethical and Quality Standards of the Mokuhyou Shinbun Group and to abide by its principles and rules. As well, to encourage the denunciation of these acts.

4. What are acts of corruption?

The law defines the harmful acts against the public administration as:

• Promise, offer or give, directly or indirectly, an undue advantage to a public agent, or the third party related to it.

• Evidently, finance, fund, sponsor or otherwise subsidize the practice of the illicit acts envisaged.

• Evidently, use of interposed individual or legal entity to hide or disguise their real interests or the identity of the beneficiaries of the acts practiced.

• Difficulty in investigating or supervising public bodies, entities or agents, or intervening in its activities, including within the scope of regulatory agencies and the oversight bodies of the national financial system.

The. Okay, but who are the public agents?

Legally, anyone who exercises, even temporarily or unpaid, by election, appointment, appointment, hiring or any other form of investiture or bond, mandate, position, job or function in organs of direct, indirect or of the Federal, State, Federal District, Municipality, Territory, of an incorporated company to the public patrimony or of entity for whose creation or cost the treasury has competed or competes with more than fifty percent of the patrimony or of annual revenue. This includes any public servants who are insolvent, elected or in charge of commission, but also employees of public companies, mixed-capital companies, municipalities, public foundations, notary offices and companies with private public partnership contracts.

B. And what can I and can not do?

Bribes, Tips and Boxes Obviously, you can not pay bribes and bribes to obtain information or advantages, even if the counterpart is legitimate and the payment is intended to facilitate a public service. But you also can not make promises or give any type of advantage or facilitation for public agents that can be linked to the Statistical Group, such as "boxes" or "tips" and small advantages like giving newspapers for public agents. You may think "everyone does". But here is where the change of culture begins.

Even though the present may be small or seemingly worthless, repeated practice can add great value and be considered an undue advantage. Travel and hospitality expenses. It is not allowed to pay courtesy and hospitality expenses (hotel room, food and entertainment expenses, etc.) to public agents, even if the money goes out of the pocket of the State Group employee, unless there is no liaison with the activities of the group and the expense is included in the private sphere of the employee or when duly approved by the Audit Committee, after formalization of an internal process justifying the legitimacy of the payment.

Bars, dinners and ballads so I can not go out with a public agent? Can not I have a meeting at lunch or dinner? Is not it. You can. The ideal is whenever each one pays his. But there are no problems in eventually being able to pay for lunches and dinners in which public agents are present. It is clear that this practice can not be recurrent and the payment of the account must be a kindness consistent with the national culture and not an extravagance that can be considered a advantage.

The Code of Ethics and Conduct sets at R $ 200,00 the maximum amount per person that can be paid sporadically at an event such as dinner and lunch. Still thus, this practice should not be recurrent. In bars and ballads, everyone must pay his. Gifts and Souvenirs The distribution of gifts, presents and souvenirs to public agents, even of low value, by Directors and Employees of the Mokuhyou Shinbun Japan Group is not allowed.

The company may, however, institutionally offer products and souvenirs of the company, with no commercial value, in the context of its marketing and promotion initiatives. Although the practice may seem common, it may be interpreted by the public authorities as an undue advantage and should therefore be avoided.

Money and Public Agents.

You should not grant a loan of movable or immovable property, securities or any kind of favor or financial concession to a public agent, whether in the context of the company's institutional activities or in private life, with respect to particular family and friendship circles. Of course, if you have a relative or close friend who is a public agent you can help him or her exceptionally in cases of need. The rule is that this is absolutely connected to your intimate relationship and not your profession. Sometimes this separation may not be very clear. So think hard and always ask for guidance from your superiors.

The same goes for providing free services to civil servants and contributions to political parties.

Personal benefit of public agents.

You should not personally promote or promote public agents, public bodies or political parties in journalistic matters, events held or sponsored by the Group or in any other way! That is to say that certain public authority should not be praised in matters directly or indirectly through its achievements in public bodies.

This should not, of course, prevent freedom of expression and the press. Public management acts, good and bad, can and should be reported and the editorial lines of the group's vehicles are free to express their opinions. Praising is different from uplifting or promoting.

5. What can happen?

In the event that a person commits an injurious act against public administration, the Group may be fined in amounts ranging from 0,1% to 20% of its gross income for the last financial year. It can reach a very high value! And in addition to the fine, in the civil sphere there can be a determination of compensation for losses, losses of assets and values, prohibition of receiving loans from public entities and even suspension of activities and compulsory dissolution of the legal entity.

The convicted legal person must also publish an extract of the conviction in a major newspaper and on his own internet site. For many companies running a picture risk is much worse than taking a pecuniary risk. But the individual who commits any of these acts may also suffer the consequences of their acts. Internally, he may suffer, for example, the penalties provided by labor legislation, that is, the warning, suspension and even dismissal for just cause. If you are a third party, you may have your contract terminated and civilly sued. Moreover, one who commits an act of corruption can always suffer the criminal and civil consequences of his acts.

6. What if I find out?

You must warn! The Mokuhyou Shinbun Japan Group depends on the cooperation of its employees to identify possible acts of corruption that may occur in its activity. If you discover or distrust any of the practices prohibited by the Code of Ethics and Conduct you may appeal to.

Communication Channels of the Internal Ombudsman. There are ways of reporting irregularities:

i. Physical Forms - you find it anywhere in the building next to the ballot box. Just complete the form, detail the irregularity and deposit in the urn.

ii. E-mail - send an email to soporte@connectionjapan.com. Tell what it is and detail everything you know or suspect.

iii. Internet - access the "Contact Us" link available in the main menu, in the institutional option.

HAVE NO FEAR! The Mokuhyou Shinbun Japan Group undertakes to avoid retaliation against employees who report irregularities committed in their activity. In the last resort, you can communicate irregularities anonymously. Of course, in this case, the trials will be more difficult, but we will do our utmost to have the facts verified and the potential culprits judged.

In accordance with Article 46, I Law 9610 / 98 e Law No. 5.250 of 9's February 1967.
Freedom of the Press LawLaw 2083 / 53 | Law No. 2.083, 12's November 1953.