text:
"Mission" shows the mission, i.e. meaning of existence, of us Coca-Cola Bottlers Japan Group to perform for the society; "Corporate Identity" is what our group employees should always remember as the foundation of management; "Culture" indicates thoughts and actions to be a company which makes contribution to the local society. "THE ROUTE" is composed of these three elements which form our corporate philosophy, and specifies the path we should take.
Our original starting point of business was route sales. As we achieve further development with our customers, we'd like to express our respect for various routes that we have taken till today, and open future routes which have unlimited possibilities.
CCBJI Group has a set of basic principles and policies on corporate management that were established to govern the business operations pursued in accordance with its corporate philosophy defined in "THE ROUTE." These operations can be achieved when employees adhere to the behavioral guidelines set forth in the Code of Business Conduct & Ethics.
By fully aligning with these basic principles and policies, and also complying strictly with the Code of Business Conduct and Ethics, our employees strive to build and maintain CCBJI as a company that continues to be highly trusted by its consumers, customers, and stakeholders.
We consider handing over global environment in sustainable form to next generations is our vital mission by effectively leveraging natural resources including water indispensable for our businesses. To this end, we drive global environmental stewardship through innovations that achieve both mitigation of environmental burden and business growth.
We also materialize CSV (Creating Shared Value) with local communities through preservation of natural environment and environmental awareness-raising therein.
1.Mitigation of environmental burden
We seek to mitigate environmental burden in our product life cycle, namely throughout the processes of procurement of materials, production, logistics, storage, sales, recovery and recycling. We also consider environmental burden in developing new products, implementing services, selecting suppliers and so on.
2.Water resource conservation
We strive to reduce water to be used for manufacturing and treat it properly. Moreover, we work on conserving water resources through collaborations with local communities in order to hand over rich water resources to next generations.
3.Mitigation of climate change
In addition to making contributions to mitigate climate change, we engage in initiatives to reduce greenhouse gas emissions at all business areas for sustainable growth of our businesses.
4.Efficient use of resources
We invest appropriate corporate resources to establish sustainable society with circular economy and to efficiently use the resources such as water and energies.
We focus on communications with stakeholders including local communities and act as a trusted company exceeding their expectations, aiming for meeting each of their needs.
6.Environmental awareness-raising
We offer various opportunities and activities of enlightenment to raise awareness on environment for those in local communities and all who are involved in our business. We also play an active role in community activities on environment.
7.Improvement of environmental performances
We work on continuous improvement of environmental performances by regularly reviewing our environmental targets proactively and as needed.
8.Compliance of laws and regulations
We set up more stringent voluntary standards according to the request of The Coca-Cola Company, not to mention our compliance to environment-related laws and regulations, ordinances and various agreements.
9.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
We will further deepen the bonds we have cultivated with our local communities over long period of time and prosper together with the society towards sustainable future.
As a company cherished by all the people, we will continuously activate communities and materialize CSV (Creating Shared Value) with the society by facing challenges tackled by the society and local communities.
1.Materializing CSV (Creating Shared Value) with society
We will materialize CSV (Creating Shared Value) by making contributions to local economies through our businesses including sales activities and generation of employment, and engage in various support in response to the challenges and issues local communities face at all times.
2.Dialogue and engagement with stakeholders in the communities
We carry out various activities with collecting the needs of local communities at all times. Upon implementing the activities, we keep in mind having dialogue and engagement with more diverse and greater number of stakeholders.
3.Guidelines on support*
When marketing is involved, we understand and comply with the policies stipulated by The Coca-Cola Company(TCCC)including "Responsible Marketing Policy" and "Global School Beverage Guidelines". Bylaws correspond to the following guidelines upon implementing activities.
・It shall align with Our Mission, Corporate Identify, and Culture.
・The priority theme to support an activity shall be "Health and Wellness", "Environment" and "Community".
・Upon supporting an event, it shall be aimed at resulting in CSV (Creating Shared Value) with society, which also enables us to win publicity, and to make diverse and greater number of stakeholders including employees engaged and participate.
・We never support organizations or entities that discriminate based on race, gender, skin color, nationality or social origin, religion, age, disability, sexual orientation, or gender identity.
・We basically do not support individuals, religious endeavors, political, legislative, lobbying or organizations.
*Note that we follow the definitions of "Organize", "Sponsor", "Partner" "Support" and "Marketing" as stated below.
Organize:Planning, execution and management of operations by us as a main role.
Sponsor:Proactive cooperation upon execution including monetary support by agreeing on the summary of a business, an activity, an event etc.
Partner:Provide support to a plan, a business, an activity, an event, a corporation or organization to expose the company name etc.
Support:All of the above
Marketing:Marketing includes all commercial advertisement that can be spread to general public through media. Key objectives of the media are to promote products or influence consumer behaviors. Communication for mainly non-profit purposes such as education and public service advertising are not included.
4.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
We always think starting from our consumers and customers and act with speed.
In order to satisfy consumers, we aim to provide more valuable products and services by discovering new needs not to mention offering products and services that meet their needs by taking voices from consumers and customers with care.
Also, our customers are important partners to satisfy consumers together with us. We aim for mutual success by not only understanding customers' sense of values and resolving their issues, but also by building trust relations through proposition making with foresight grasping needs not yet noticed by customers.
And in carrying out communication, we will handle confidential and personal information with due diligence, respecting privacy and personal information of everyone including consumers and customers.
1.Consumer satisfaction policy
(1) We carry out sales activities for greater satisfaction by always offering safe and sound products and services.
(2) We generate new ideas and create values by thinking and acting with "consumer-centricity" and offer joy and excitement to consumers.
(3) We listen to voices of consumers with appreciation and deliver satisfaction convincing to consumers by incorporating them to enhancement of products and services.
(4) We adhere to laws and regulations as well as internal regulations on consumer protection in order to protect privacy of consumers.
(5) We shall respond to inquiries and complaints from consumers promptly, appropriately and sincerely.
2.Customer satisfaction policy
(1) We carry out sales activities with a spirit of co-existence and co-prosperity by assuming a role as the best partner to enable business development and growth of customers.
(2) We continue to be a trust-worthy, reliable corporation through provision of beneficial information and services to customers by thinking and learning together with them for their struggling challenges.
(3) We discover consumers' potential needs for customers by always thinking in their position and propose valuable shoes products and services.
(4) We listen to voices of consumers with appreciation and deliver satisfaction convincing to customers by incorporating them to enhancement of products and services.
(5) If any issue arises in dealing with customers, we shall respond promptly, appropriately and sincerely.
3. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
1.Meaning of "Personal Information"
"Personal Information" means any information that allows identifying an individual, including name, postcode, address, telephone number, age, date of birth, gender, profession, and e-mail address.
2.Gathering and Using Personal Information
CCBJI Group may gather and use the customers' personal information among its group or in cooperation with companies in the
Coca-Cola System listed in *2 (hereafter "Coca-Cola System Companies") for the purpose of offering a variety of services to its customers, which include: prize contests and other promotional campaign activities; response to inquiries and requests from the customers, and membership-based services for providing information on products, events and other subjects. Also, CCBJI Group may gather and use personal information in cooperation with retail stores, etc. (CCBJI Group's clients, etc.) in the context of prize contests, other promotional campaign activities and inquiries/request from the customers.
CCBJI Group will gather its customers' personal information within the scope that is reasonable and necessary, indicate the purpose of use and the presence of any joint users, and clearly state that customers should provide their personal information on their own discretion. If it should be necessary to make use of personal information beyond the preliminarily indicated scope, CCBJI Group will notify or announce the new purpose of use, and customers will be free to accept or refuse this.
Note that customers who do not wish to provide their personal information or do not consent to new purposes of use may not be able to use services for which personal information is essential.
In addition, for the purpose of preventing crimes, we have security cameras installed in some of the vending machines that are set to start filming when a criminal act or abnormity takes place.
Typical cases in which Personal Information is used among CCBJI Group or jointly with Coca-Cola System Companies include:
(1)When receiving inquires or requests from the customers
The parties making joint use of personal information will be CCBJI Group and Coca-Cola System Companies, and CCBJI will be responsible toward the customers for managing their personal information.
Information used jointly is for responding to a request including the address, name, and telephone number, etc. of the person filling the request.
Please be advised that we may conduct a follow-up research regarding the responses to customer inquiries to the extent that is necessary and reasonable for the purpose of improving customer services.
(2)When engaging in product sales, promotional activities or the repairs/maintenance of sales equipment or other maintenance work
The parties making joint use of Personal Information will be CCBJI Group and Coca-Cola System Companies, and CCBJI will be responsible towards its business partners for managing the personal information.
Information used jointly is the name and contact information of the business partners (and the representative of business partners) that are required for transactions.
(3)When CCBJI Group is conducting prize contents and other promotional campaigns
The party making joint use of personal information will be CCBJI Group; CCBJI will be responsible toward the customers for managing the personal information.
The address, name, age, and telephone number, etc. of the applicants and other information necessary to select and notify the winners are used jointly.
With the exception of cases where CCBJI clearly explains the purpose of use and the customer gives his/her consent, during promotional campaigns the personal information of applicants will not be stored on a continuous basis, excluding information on the winners of prize contests, which will be stored for a given period of time.
Note that applicants cannot win in multiple promotional campaigns held simultaneously and targeting the same product due to restrictions imposed by the Act Against Unjustifiable Premiums and Misleading Representations. In order to avoid such instances, CCBJI may collate the winners' lists with the promotional campaign's organizers.
Personal information that CCBJI obtained by March 31, 2005, which is prior to the effective date of Act on the Protection of Personal Information (Put into force in its entirety on April 1, 2005), shall be continually used for the purpose described above.
3.Managing and Protecting Personal Information
Personal information provided by the customers will be managed appropriately on the administrators' responsibility. CCBJI Group will endeavor to protect personal information by taking reasonable and necessary measures against illicit external access, loss and damage. CCBJI Group may also consign the handling of personal information to a contractor within the scope that is necessary to provide better services. In such cases, CCBJI Group will ensure that the contractor manages and protects personal information appropriately by taking measures such as imposing on them the obligation through the conclusion of a contract and taking other steps.
4.Avoiding the Provision of Personal Information to Third Parties
CCBJI Group will not provide customer's personal information to any third party unless:
(1)The customer gives his/her consent;
(2)The personal information is to be used jointly with a joint user as stipulated in 2. Above;
(3)CCBJI Group consigns the handling of personal information to a contractor within the scope that is necessary to provide better services as stipulated in 3. Above;
(4)The provision of personal information is necessary to protect lives and bodies of human beings or properties, and acquisition of the consent of the customer is difficult;
(5)The provision of personal information is legally requested by the police or another public institution;
(6)Other cases such that the provision and disclosure of personal information is found legally accepted pursuant to laws and ordinances.
5.Disclosing Personal Information Held by CCBJI Group
If a customer wishes for his/her personal information to be disclosed (*3), CCBJI Group will, in accordance with the Act on the Protection of Personal Information and based on procedures stipulated by CCBJI Group, disclose the customer's personal information that it holds for the period stipulated by laws and ordinances without delay and upon conducting any necessary examination, etc., unless:
(1)There is a risk to the life, body, assets or other rights and interests of the customer or a third party;
(2)There is a risk of significantly hindering CCBJI Group's business;
(3)Disclosure violates laws and ordinances.
6. Making Corrections/Additions to, Deleting or Suspending the Use of the Personal Information held by CCBJI Group
If a customer wishes for any correction/addition to be made to his/her personal information held by CCBJI Group, or for such personal information to be deleted (hereafter "corrections, etc.") (*3), CCBJI Group will, in accordance with the Act on the Protection of Personal Information and based on procedures stipulated by CCBJI Group, make corrections, etc. to the personal information of the customer or the business partner that it holds for the period stipulated by laws and ordinances without delay and upon conducting any necessary examination, etc.
Likewise, if the customer wishes for CCBJI Group to stop using his/her personal information to provide e-mail notifications and other information services (hereafter the "suspension of use"), CCBJI Group will, in accordance with the Personal Information Protection Law and based on procedures stipulated by CCBJI Group, stop using the personal information without delay and upon conducting any necessary examination, etc.
7.Important Note
This Privacy Policy covers the websites managed and operated by CCBJI Group. CCBJI Group's website may show links to external websites, etc. Not managed or operated by CCBJI Group; note that CCBJI Group is not responsible for services offered by external websites, etc. not managed or operated by CCBJI Group
8.About this Privacy Policy
This Privacy Policy may be reviewed and revised as appropriate. In such cases, the revised version will be posted on the website.
Contact us at the companies listed below for anything you should wish to inform us of in advance with this Privacy Policy, and for any other inquires on personal information.
To the inquiry form
*1 Coca-Cola East Japan Group Companies stipulated in Privacy Policy of CCBJI Group are:
Coca-Cola Bottlers Japan Holdings Inc.
Coca-Cola Bottlers Japan Inc.
Coca-Cola Bottlers Japan Vending Co., Ltd.
FV Japan Co., Ltd
Kadiac Co., Ltd
Coca-Cola Customer Marketing Company Co
Coca-Cola Bottlers Japan Business Services Inc.
Coca-Cola Bottlers Japan Benefit Co., Ltd.
*2 The Coca-Cola System companies stipulated in "2. Gathering and Using Personal Information" of CCBJI Group's Privacy Policy are:
Coca-Cola (Japan) Company, Limited
Hokkaido Coca-Cola Bottling Co., Ltd.
Michinoku Coca-Cola Bottling Co., Ltd.
Hokuriku Coca-Cola Bottling Co., Ltd.
Okinawa Coca-Cola Bottling Co., Ltd.
*3 About the procedures stipulated by CCBJI Group in Privacy Policy "Disclosing Personal Information Held by CCBJI Group" and "Making Corrections/ Additions to, Deleting or Suspending the Use of the Personal Information Held by CCBJI Group."
1.Procedure Followed When a Customer Wishes for the Personal Information Held by CCBJI Group to Be Disclosed
If a request is made to disclose personal information held for the period stipulated by laws and ordinances in accordance with the Act on the Protection of Personal Information, CCBJI Group will disclose said personal information upon verifying the identity of the person filing the request.
CCBJI Group will accept requests for the disclosure of personal information sent via post upon enclosing the required documents, stipulated in (1) and (2) below. If the documents stipulated in (1) and (2) that are submitted allow identifying the person filing the request, CCBJI Group will disclose the personal information of the person filing the request by delivering documents via post. CCBJI Group will be unable to comply with a request if it is unable to identify the person filing the request based on the documents that are sent in. Note that the documents you send may not be returned to you.
(1)Request for Disclosure (523KB)
Please fill in the required entries on the form prescribed by CCBJI Group and post it together with the identification documents stipulated in (2).
(2)Identification Documents
Documents that allow verifying the address and name registered at CCBJI Group, and are issued by administrative authorities or an institution deemed equivalent by CCEEJ Group; these include official copies of family registers, copies of driver's licenses, health insurance cards, and other certificates.
In case the request for disclosure is made through a representative, documents allowing the identification of both the person filing the request and his/ her representative, as well as a letter of attorney to a representative bearing the name, address, and seal of the person filing the request
(3)Send to
Person in charge of Personal Information Disclosure, Coca-Cola Bottlers Japan Incorporated
Tokyo Midtown Tower, 9-7-1 Akasaka, Minato-ku, Tokyo 107-6211
2.Procedure followed When a Customer Wishes for Corrections, etc. to be Made to the Personal Information Held by CCBJI Group or for the Suspension of Use
When a customer wishes for corrections, etc. to be made to the personal information held by CCBJI Group for the period stipulated by laws and ordinances, or for the suspension of use in accordance with the provisions of the Act on the Protection of Personal Information, CCBJI Group will, as in cases where a customer wishes for the disclosure of the personal information held by CCBJI Group, carry out the necessary procedures upon verifying the customer's identity, as follows. Requests for making corrections, etc. to personal information or for the suspension of use will be accepted via post sent to the address shown below upon enclosing required documents ((1) and (2)) shown below. If the documents stipulated in (1) and (2) that are submitted allow identifying the person filing the request, CCBJI Group will make the desired corrections, etc. to personal information or suspend its use, and will notify the customer in writing. CCBJI Group will be unable to comply with a request for corrections, etc. or for the suspension of use if it is unable to identify the person filing the request based on the documents that are sent in. Note that the documents you send may not be returned to you.
(1)Application Form for Correction, etc./Suspension of Use (PDF:565KB)
Please fill in the required entries on the form prescribed by CCBJI Group and post it together with the identification documents stipulated in (2).
(2) Identification Documents
Documents that allow verifying the address and name registered at CCBJI Group and issued by administrative authorities or an institution deemed equivalent by CCBJI Group; these include official copies of family registers, copies of driver's licenses, health insurance cards, and other certificates.
In case the request for disclosure is made through a representative, documents allowing the identification of both the person filing the request and his/ her representative, as well as a letter of attorney to a representative bearing the name, address, and seal of the person filing the request
(3) Sent to:
Person in charge of Personal Information Disclosure, Coca-Cola Bottlers Japan Incorporated
Tokyo Midtown Tower, 9-7-1 Akasaka, Minato-ku, Tokyo 107-6211
CCBJI Group's procedures for disclosing and making corrections, etc. to the personal information will not require any expenses on part of the users of CCBJI Group's services. In cases 1. and 2. above, however, customers will bear the postage expenses for the documents sent to CCBJI Group for the requested procedures. Service users may also incur expenses when preparing documents for identification.
4.Procedures for the Disclosure of Personal Information and Corrections, etc.
The procedures for disclosing or making corrections, etc. to the personal information stipulated below may be reconsidered and revised as appropriate. In such cases, the revised version will be posted on the website.
Contact us below for any inquires on the procedures for disclosing personal information or on matters not mentioned above.
To the inquiry form
1. Name of the company
•Coca-Cola Bottlers Japan Holdings Inc.
•Coca-Cola Bottlers Japan Inc.
•Coca-Cola Bottlers Japan Vending Co., Ltd
•FV Japan Co., Ltd
•Kadiac Co., Ltd
•Coca-Cola Customer Marketing Company Co
•Coca-Cola Bottlers Japan Business Services Inc.
•Coca-Cola Bottlers Japan Benefit Co., Ltd.
2. Compliance with relevant laws, regulations, guidelines, etc.
CCBJI Group will comply with the "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure", "Act on the Protection of Personal Information", and "Guidelines for the Proper Handling of Specific Personal Information (for Private Entities)" to ensure the proper handling of specific personal information.
3. Security control measures
As to the security control measures for specific personal information, we have separately established the "Regulations for the Protection and Handling of Specific Personal Information" and "Standards for the Safety Management and Handling of Specific Personal Information".
4. Contact for inquires
Contact the link below for any inquiry or opinion regarding CCBJI Group's handling of specific personal information.
Click here for inquiry form
5. Improvements
CCBJI Group will constantly make improvements in order to ensure the proper handling of specific personal information. We will also reflect such improvements in the basic policy from time to time.
We will offer safe, trust-worthy, fresh and refreshing products and services to consumers and customers anytime, anywhere and to anyone. To this end, we will work to ensure and improve quality in all operation processes by considering quality as the top priority matter.
1.Basic principle for quality
(1) Each of our Functions is aware of its roles and responsibilities and implements customer-driven quality control.
(2) We will perform our daily work with the top priority on "quality".
(3) Each one of us keeps in mind and thinks about "quality" at all times and takes an action to enhance our brand value.
2.Supplemental Provision
The policy is enacted and enforced effective January 1, 2018.
・Service: Comprehensive activities including the means of providing products.
・Quality Assurance:Systematic structure to continuously assure quality which allows customers to feel safe and satisfied when purchasing and using.
・Quality Control:Systematic measures to sustainably create quality and services that meet the requirements of customers.
As a company staying close to an everyday life of consumers, we will offer valuable products and services that meet needs and tastes of wide range of generations by always considering health and wellness as top priority.
In addition, we will strive to help people maintain and enhance wellness through raising awareness for a proper eating and drinking habit and providing opportunities to enjoy sports, and will propose active and healthy lifestyles.
1.Disseminate information on products and services
(1)We work hard to offer products and services that contribute to maintenance and enhancement of health and wellness including FOSHU (Foods for specified health uses) and FFC (Foods with Function Claims) together with partner companies such as Coca-Cola (Japan) Co., Ltd.
(2)We also strive to provide comprehensive and sufficient information related to health and nutrition through indications on packages and explanations on website etc.
2.Awareness raising and provision of programs
We will widely communicate active and healthy lifestyles through various media through our efforts to spread correct knowledge on health and nutrition. We will actively conduct various seminars to prevent heatstroke or lifestyle diseases as well as health-related programs.
3.Compliance of laws and regulations
We comply to health-related laws and regulations, ordinances, various agreements and voluntary standards. We also strive to gather related information at all times and respond speedily and appropriately while closely coordinating with relevant administrative agencies, industrial organizations, NPO/NGO, academic/practitioner experts, partner companies and others.
4.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
We carry out speedy decision makings strong to changes by raising transparency and efficiency of management based on the positions of each and every stakeholder including customers, local communities, shareholders and employees in addition to consumers, in order to realize mid- to long-term corporate value enhancement.
We also reinforce governance to ensure sound corporate management by setting up basic policy on internal control system and carrying out appropriate management of risks and information.
1. System to ensure that performance of duties by Directors and employees of Coca-Cola Bottlers Japan Holdings Inc. (hereafter to be referred to as "CCBJH") and Group companies comply with laws and regulations and the Articles of Incorporation.
(1) The code of conduct shall be established in order to ensure that all the Directors, Executive Officers, and employees of CCBJH and Group companies (hereafter to be referred to as "Our Group") comply with laws and regulations and the Articles of Incorporation to act in conformity with social norms. The Risk Management Committee shall be convened periodically in order to reinforce the compliance system and to prevent non-compliance.
(2) An internal whistle-blowing system against non-compliance, namely, a reporting and consultation contact separate from the reporting line to immediate managers, shall be set up.
(3) The oversight function of the Board of Directors shall be reinforced by adopting the company system where Audit and Supervisory Committee is established in order to ensure auditing by the Audit and Supervisory Committee where more than a half of the constituent members are External Directors.
(4) The department in charge of internal auditing shall be established in order to audit whether business activities are conducted appropriately and effectively in conformity with laws and regulations, the Articles of Incorporation, Company Rules and Regulations, etc.
(5) The Company clearly identifies the firm stance against anti-social forces and organizations that cause threats to the orders and safety of civil society and that the Company never ties with such entities. The Company shall never accede to any illegal request and deal with any such request in cooperation with the police.
2. System to retain and manage information related to Directors' performance of their duties
(1) The Company shall record information regarding minutes of General Shareholders meetings, minutes of Board of Directors meetings, documents and other materials related to important decision-makings and Directors' performance of their duties in documents or electronic media and retain it in accordance with the Rules of Documentation Handling and Information Security Policy in a manner similar to that for statutory documents.
(2) The Company's Directors may inspect such documents, etc. at any time.
3. Regulations and other systems concerning loss risk management of Our Group
(1) In accordance with Our Group policy on responding to material business risks and from the viewpoint of management of other risks, significant items shall be reported to the Risk Management Committee, and the Risk Management Committee shall determine policies to accommodate the risks as required.
(2) The Company establishes rules/guidelines and maintains an organization to execute effective response to material risks, and ensure the matters to be passed down by establishing manuals and implementing training for the entire Group.
(3) The department in charge of risk management in the Company or its subsidiaries is to monitor the condition of company-wide risks, and take appropriate measures on a group-wide basis.
4. System to ensure efficiency of performance of duties by Directors of Our Group
(1) The Board of Directors shall determine Group-wide management policy and goals shared by the Directors, Executive Officers, employees and others of Our Group, and determine the efficient method to achieve the goals including the allocation of authority based on the group's decision-making rules.
(2) In addition to Board of Directors Meetings, appropriate forums such as the Management Meeting shall be organized to deliberate significant matters affecting the entire CCBJI Group, thereby ensuring that decisions are reached based on considerations of multi-dimensional aspects.
5. System to ensure appropriateness of operations in a corporate group, which consists of the Coca-Cola Bottlers Japan Inc. and its subsidiaries
The Company shall ensure management integration of Our Group through establishment of a corporate philosophy, management policy, code of business conduct and Chart of Authority common throughout Our Group and supervise and manage the performance of the subsidiaries' operations.
6. Matters concerning employees assisting the Audit and Supervisory Committee to execute the duties if the Audit and Supervisory Committee request the assignment of such employees, matters concerning the independence of such employees from directors (excluding directors serving on the Audit and Supervisory Committee) and matters related to ensuring the effectiveness of instructions given by the Audit and Supervisory Committee to such employees
The Company shall assign employees assisting the Audit and Supervisory Committee. Such employees shall execute the duties under the instructions given by the Audit and Supervisory Committee in assisting executions of duties by the Audit and Supervisory Committee and shall not receive instructions from directors(excluding directors serving on the Audit and Supervisory Committee).
7. System for reporting by Directors and employees of Our Group to the Audit and Supervisory Committee and systems to ensure that reporting parties do not receive disadvantageous treatment as a result of such reports
(1) Upon discovery of any incident that could cause Our Group substantial damage such as acts in violation of laws and regulations, the Directors (excluding Directors serving on the Audit and Supervisory Committee), Executive Officers, employees and others of the Company shall immediately report the matter to the Audit and Supervisory Committee.
(2) The Internal Audit Department and the Risk Management Committee shall regularly report internal audit results and the status of other activities in Our Group to the Audit and Supervisory Committee.
(3) The department in charge of compliance shall regularly report the status of whistleblowing in Our Group to the Audit and Supervisory Committee.
(4) It is prohibited to treat unjustly of the reporter who reported to the Audit and Supervisory Committee, and the Company shall ensure that this matter would be passed down to all the executives and employees of the group.
8. Matters concerning procedures for advance payment or reimbursement of expenses incurred in the course of performance of duties by Directors serving on the Audit and Supervisory Committee and policies related to processing expenses or liabilities arising from performance of duties by Directors serving on the Audit and Supervisory Committee
The Company establishes enough budget for Directors serving on the Audit and Supervisory Committee each year to fulfill the performance of their duties.
9. Other systems to ensure that the Audit and Supervisory Committee's audit is conducted effectively
(1) The Representative Director and the Audit and Supervisory Committee shall hold a meeting on a regular basis to exchange opinions in order to communicate with each other.
(2) The Representative Director shall prepare an environment so that the Audit and Supervisory Committee is able to cooperate with external experts such as lawyers and certified public accountants in the course of its duties whenever it deems it necessary.
(3) The Audit and Supervisory Committee shall regularly provide opportunities for the exchange of opinions with the Internal Audit Department and accounting auditors.
10. Supplementary Provisions
The policy is enacted and enforced effective August 1, 2017.
The policy is revised and enforced effective January 1, 2018.
1.Relationship with the shareholders
(1) Ensuring the rights for the shareholders
① Based on the importance of the rights for the shareholders, we will make an effort to ensure appropriate correspondences so that the rights for all shareholders will be ensured.
(2) Interaction with the shareholders
① We acknowledge that shareholders' meeting is an opportunity for holding constructive interactions with the shareholders, and will make an effort to develop the environment that is appropriate for all shareholders to execute their rights, and to provide adequate and easy-to-understand information. Additionally, in case a certain number of dissentient vote is made for any of the agenda proposed by the company at the shareholders' meeting, we will implement cause analysis for the reason why there were so many dissentient votes, and will ensure to execute our accountability in order to let the shareholders understand our ideas through holding interactions with the shareholders.
② We will make an effort to let our Directors and Group Executive Officers to send out information on a regular basis so that we can promote understanding of the shareholders towards ourselves and to lead such understanding onto sustainable success and improvement in mid- to long-term corporate value via holding interactions with the shareholders, and will also make an effort to ensure information management and prevention in leakage of insider information.
(3) Capital policy
① We will implement the capital policy that will enable reinforcement in the financial structure aiming for improvement in corporate value, and enable active redistribution of profits to the investors and shareholders.
② Our basic policy is not to retain shares for political purposes. However, there may some cases where we obtain and retain shares for the purpose of creating business opportunities and of establishing, maintaining, and reinforcing the relationship with our partner companies and with the regional communities.
Please be reminded that regarding the major shares retained for political purposes, efforts will be made to ensure evaluation and reporting regarding their holding cost and investment return in an appropriate manner.
2.Relationship with stakeholders other than the shareholders
(1) We will gain trust from various stakeholders such as the consumers, customers, regional communities, and employees, etc. by clarifying the significance or our existence, and by conducting the activities which provide values to each stakeholder, and therefore work upon improving our corporate value.
① We will pursue the satisfaction of our consumers' and our customers' by acting based on the viewpoints of our consumers' and customers' to provide products and services of better quality.
② We will aim to execute our social responsibilities and to contribute for rich and sustainable society as a corporate citizen, and will ensure preventive measures for environmental risks by taking care for environmental issues in various scenes among out business activities.
③ We will make an effort to establish the workplace environment where each individual employee is respected, where various senses of value and lifestyles are accepted, and where the possibilities and capabilities for each individual can be exercised to the highest extent including female employees taking on active roles.
3.Information disclosure and ensuring of transparency
(1) Appropriate information disclosure
① We will ensure appropriate disclosure of information regarding the financial status, financial data such as business management performances, and non-financial information such as those information regarding the management strategy, management issues, and risks and governance, etc. in accordance with the law, and will also work upon proactively providing information other than those required to be disclosed by the law.
② Based on the understanding that the information disclosed / provided will be the basis for holding constructive interactions with the shareholders, we will make an effort to provide accurate and easy-to-understand explanations.
(2) Ensuring transparency
① We bear in mind that external accounting auditors hold an important responsibility for the shareholders and investors, and will implement appropriate correspondences in order to ensure adequate auditing.
4.Corporate governance structure
(1) The basic concept of the corporate governance structure
We will design optimum organizations in order to establish a structure which enables improvement in management soundness, transparency and efficiency, and therefore improve corporate value and shareholders' value in the medium to long term.
5.Group management and decision making
(1) The basic concept of group management
We will ensure business management for the entire group as a one team, in a manner as if the entire group is a single company.
(2) The basic concept regarding the distribution and delegation of decision making authority
In order to ensure appropriate and smooth group business operations, decision making authority will be appropriately distributed and delegated to the company resolution organization and those members of management positions.
Additionally, in order to be able to promptly respond to the needs of the consumers' and customers' and to the changes in the market, we will develop a structure where the organizations closely related to the gemba (actual work site) can make decisions in a prompt and simple manner.
(3) Basic rules regarding the authorities and responsibilities
Clear scope of jobs and the authorities required for executing such jobs will be provided to each resolution organization and person with management positions. The resolution organizations and persons with management positions will be responsible for the results caused by having executed or not executed such authorities.
6.Supplementary provisions
This Policy shall come into force from January 1, 2018.
1.Implementation structure
Information regarding risk management will be consolidated and have central management ensured, whereas decisions regarding them will be made in a transparent, fair, prompt, and accurate manner.
(1) Activities for managing risks that have materialized
"Additionally to implementing initial response for the accidents and incidents that have occurred in an appropriate and prompt manner, we will thoroughly identify, assess, and respond to the risks that have materialized, investigate the cause for such materialization, and execute recurrence prevention."
(2) Activities for preventing potential risks
"We will acknowledge the risks that may materialize in the future, or the potential risks at an earlier timing, and execute the activities for preventing them from materializing."
3.The basic concept
(1) We will make an effort to minimize the negative impact that would be provided onto business operation.
(2) We will prioritize the safety and health of the local communities and the stakeholders at the highest priority.
(3) We will maintain the brand image and reputation for Coca-Cola System and its products.
(4) We will conform to all laws and regulations, social rules, and code of business conduct / regulations / other internal rules for the Group that are applied onto business operation.
(5) We will correspond to the regional communities and the stakeholders in an earnest and sincere manner.
4.Preparing operational manuals
This Policy is specifically stipulated by other regulations and operational manuals, and are being executed.
The employees of outsourced business partners' who are closely related with CCBJI Group's businesses are also requested to understand the concept of this Policy, and to implement appropriate actions.
6.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
1. Information and environment that are subject to this policy
(1) All information arising from the Company's business activities (regardless of forms, such as documents, data and memories)
(2) All computer devices, networks, facilities, equipment and fixtures used in the Company's business operations
2. Basic principles to follow when using operation systems and computer devices
(1) Compliance with laws and regulations related to information security, this policy, and company rules
(2) Compliance with rules on the use of the IT environment
(3) Adherence to information handling authorities
(4) Prohibition of taking out and using devices and information for purposes other than the original intent
(5) Implementation of measures to prevent information leakage
(6) Implementation of measures to prevent malware infection
(7) Implementation of periodic security training
3. Basic principles to follow when developing systems and creating a database
The Company shall establish, maintain and strictly control the IT system environment and facilities, etc. that contain such systems, allowing only relevant employees to access them and properly protecting them from such threats as wiretapping, destruction, loss and suspension, within the scope necessary for business continuity.
4. Information security training
The division responsible for information security shall provide information security training to officers and employees of the Company on a regular schedule. New employees and mid-career employees shall also be provided with information security training as necessary.
5. Protection of facilities
Facilities that store the Company's information assets, such as the head office, plants, sales centers, warehouses and all other CCBJI Group facilities, shall be properly protected from such threats as intrusion, theft, destruction, disappearance and falsification, in accordance with separately defined rules on security of facilities.
6. Violation of this policy
Any CCBJI Group employees who intentionally or negligently violate this policy and cause serious security infringement shall be dealt with strictly in accordance with internal rules.
7. Implementation of information security audits
The Company shall implement, both periodically and as necessary, information security audits of the information security framework that the Company should adhere to and of suppliers who handle classified information of the Company, based on relevant laws and regulations.
8. Information security strategies
The Company shall define and execute information security strategies with the aim of identifying security risks that could obstruct its business activities and limiting their impact within an acceptable range.
9. Other (scope of application)
This policy shall be applied not only to officers and employees of the CCBJI Group but also to those who are involved in the Company's operations on consignment from the CCBJI Group.
10. Supplementary clause
The policy is enacted and enforced effective January 1, 2018.
1.Disclosure Principles
Coca-Cola Bottlers Japan Holdings Group (hereafter "Our Group") discloses information in a timely and appropriate manner under the principles of transparency, fairness and sustainability with the aim of gaining trust from society so that domestic and overseas stakeholders, including shareholders and investors, can properly understand and evaluate Our Group.
Our Group disclose information according to the Companies Act, the Financial Instruments and Exchange Act, and other laws inside and outside Japan, as well as rules on the timely disclosure of corporate information stipulated in the Securities Listing Regulations of the listed exchange (hereafter Timely Disclosure Rules) and other rules. Our Group proactively provide information deemed relevant for investment decisions and understanding of Our Group even when the information is not subject to the Timely Disclosure Rules.
2.Disclosure Method
Information subject to the Timely Disclosure Rules is promptly published on the corporate website following disclosure via the Timely Disclosure Network (TDnet) provided by the Tokyo Stock Exchange.
Regarding information that is not subject to the Timely Disclosure Rules, Our Group strive to ensure that stakeholders have access to relevant information by posting materials on the corporate website, webcasting company earnings presentations, etc. when the information is deemed important for making investment decisions and understanding Our Group.
3.Handling of Earnings Forecasts and Future Information
Any forward-looking statements, including plans, performance forecasts and strategies, are based on the assumptions and judgment of the management of Our Group in view of data and information available as of the date the material is released. Therefore, these forecasts may differ materially from actual performance due to various risks and uncertain factors. These risks and uncertain factors are included in company earnings materials in the Forward-looking Statements notice.
4.Handling of Insider Information (Designation of Quiet Period)
From the day after the quarterly settlement day to the announcement of the financial results, Our Group enter into a Quiet Period to refrain from making comments or responding to questions on financial results of the most recent settlement period and/or performance forecasts in order to prevent inappropriate disclosure of financial information and to maintain impartiality. However, Our Group may respond to questions during the Quiet Period if they are under the scope of information previously disclosed or otherwise publicly available.
Our Group endeavor to disclose information in a timely and appropriate manner in accordance with the Timely Disclosure Rules when there is any new information that is subject to these rules or when there is a material difference in expectations versus previously disclosed earnings forecasts.
5.Supplementary provisions
The policy is enacted and enforced effective January 1, 2018.
1.We pay taxes properly in accordance with tax-related laws and regulations.
2.We conduct appropriate tax management, always ensuring that there are no omissions or delays with regard to tax-related accounting and other associated actions.
3.We conduct efficient and continuous tax management in light of maximizing shareholders' value. We do not avoid taxes through interpretation/application that deviates from the purpose of relevant laws and regulations.
4.We maintain good relations with tax authorities through smooth communication with them and sincerely respond in good faith to ensure transparency and credibility in relation to tax practice.
We respect human rights and observe all rules, laws and regulations by aiming to become an excellent company equipped with hinkaku (dignity). We, then conduct right behaviors with dignity following socially good conscience and will raise corporate value by gaining trust from all stakeholders.
To achieve this goal, individual employee not only has a sense of awareness as a person representing the company but also will act having accountability to own behaviors with integrity and honesty according to rules, laws and regulations.
Activities of suppliers that extend support to our actions are also important in order to gain trust from stakeholders. We will build a constructive and better relations with suppliers that conduct right behaviors respecting human rights and observing rules, laws and regulations.
1.Respect for Human Rights
Our Group respects human rights. Respect for human rights is a fundamental value of Our Group, and our aim is to help increase the enjoyment of human rights within the communities in which Our Group operates.
This policy applies to Our Group, the entities that Our Group owns, the entities in which Our Group holds a majority interest, and the facilities that Our Group manages.
Our Group develop a due diligence process for human rights as a means to identify, prevent, and mitigate human rights risks of the business partners in our business and value chain. When an overt or latent adverse impact on human rights are identified in the course our business activities, we will strive to prevent and mitigate such impact in a rightful and fair manner. If Our Group's business activities are found to have been engaged in adversely impacting affairs directly or through relationship with a third party, we will remedy such issue or strive to provide equivalent support via appropriate procedures and work on the prevention of reoccurrence.
2.Community and Stakeholder Engagement
We recognize that we impact the communities in which we operate.
We work with stakeholders in each community to listen to their opinions, learn from them, and reflect them in our business activities.
We strive to communicate with stakeholders, as necessary, with respect to human rights issues related to our business.
3.Diversity and Inclusion
We value and advance the diversity and inclusion of the people with whom we work. We are committed to the promotion of equal opportunities and are intolerant of discrimination and harassment at workplaces. We work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, color, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, political opinion or any other status protected by applicable laws. The basis for recruitment, hiring, placement, development, training, compensation and advancement at Our Group is qualifications, performance, skills and experience. We do not tolerate disrespectful or inappropriate behavior, unfair treatment or retaliation of any kind, regardless of any personality or status. Harassment is not tolerated not only inside but outside the workplaces.
4.Freedom of Association and Collective Bargaining
We respect our employees' right to form a labor union without fear of reprisal, intimidation or harassment. Furthermore, we strive to exchange constructive dialogues with the labor union and deliver negotiation in good faith.
5.Workplace Security
We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats.
Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.
6.Forced Labor
We prohibit the use of any forms of forced labor.
7.Prohibition of Child Labor
We prohibit the hiring of individuals that are under 18 years of age for positions that entail hazardous work, pursuant to relevant laws and regulations.
8.Work Conditions
We operate our business in compliance with laws and regulations applicable to wages, work hours, overtime work, and benefits.
9.Healthy Lifestyles
We are committed to providing transparent nutrition information and a range of beverage options to enable consumers to make informed choices consistent with a healthy lifestyle.
10.Guidance and Reporting for Employees
We strive to create workplaces in which open and honest communications among all employees are valued and respected.
We are committed to comply with applicable labor and employment laws wherever we operate.
Any employee who believes there is a conflict between the language of this policy and applicable laws, customs and practices; who has questions or concerns about this policy; or recognize an action that may violate this policy; are required to contact his/her manager, HR staff in charge, or the internal or external Ethics & Compliance Reporting Hotline, who makes every effort to maintain confidentiality.
No reprisal or retaliatory action will be taken against any employee for raising concerns under this policy. We will investigate, address and respond to the concerns of employees and will take appropriate corrective action in response to any violation.
The Human Rights Policy is aligned with Our Group's Code of Business Conduct and Ethics.
11. Scope of Application
This policy is applicable to all the officers and employees of Our Group. In addition, we require our business partners to respect the Articles 3, 5, 6, and 7 herein.
12. Enforcement Date
This policy shall be effective as of January 1st, 2018.
1.Policy Summary
The nature of the business of Coca-Cola Bottlers Japan Group requires that we interact with various government officials, etc (as defined later). The laws and ordinances, CCBJI Group Code of Business Conduct & Ethics, and this Policy establish certain limits on the interactions with government officials, etc., particular where we might be providing something of value to a government official, etc.
This policy is intended to provide our employees with a level of awareness about laws and regulations associated with anti-bribery in order to avoid inadvertent violations as well as to recognize potential issues in time for them to be addressed appropriately. A violation of laws and regulations associated with anti-bribery can lead to severe administrative and criminal penalties; therefore it is vital that we not only understand and appreciate the importance of this Policy, but comply with it in our daily work.
Under this policy, the offering or acceptance of corrupt payment and other advantages between private (non-government) persons and entities shall constitute commercial bribery and be prohibited.
2. Policy Applies To/ Eligibility
This Policy applies to all employees of Coca-Cola Bottlers Japan Group (hereinafter referred to as "the Company"), including officers.
3.Policy Background
The Company must carry on its business with integrity based on the Code of Business Conduct & Ethics. This means avoiding corruption of all kinds, including bribery of government officials, etc.
The Company has employees from many countries and conducts business activities globally such as procurement from overseas; thus, it is important to comply with laws and regulations associated with anti-bribery in the countries and areas where our business partners locate in addition to those in Japan.
In addition, the Company has incorporated a prohibition against bribery into our Code of Business Conduct & Ethics, and this Policy provides explanation on the prevention of improper payments and permissible payments under all laws and regulations associated to anti-bribery that we must comply with (the criminal law, Unfair Competition Prevention Act, National Public Service Ethics Act , the Companies Act, U.S. Foreign Corrupt Practices Act (hereinafter referred to as "FCPA"), and the U.K. Bribery Act (hereinafter referred to as "UKBA") and, China Unfair Competition Prevention Act (hereinafter referred to as "CUCPA"), etc. These laws and ordinances will be collectively referred to as "Applicable Corruption Laws" in this Policy.
When Applicable Corruption Laws are violated, in many cases, the person violated the laws will be sentenced or fined regardless of his/her nationality. Moreover, it is possible that the Company is fined also, which creates massive damage to the trust and reputation of the Company as well as to the Coca-Cola business.
For the purposes of this Policy, the term "Government Official" is broadly defined to include:
(1)Any officer or employee of any government entity, department, or agency
(2)Any employee of a national or public-owned business, school, hospital, or other entity
(3)Any political party, officer, or employee thereof
(4)Any politician or candidate for political office
(5)Any employee or official of a public international organization, department, or agency thereof (e.g., the United Nations, Olympic Organizing Committee, FIFA Committee, and World Bank)
(6)Any person acting in an official capacity on behalf of a government entity
(7)Deemed public servants (officers or employee of those entities (public corporation, institution, fund, incorporated administrative agency, and promotion association) deemed to be public servants by the laws and regulations *)
*If any concern arises on how to correspond with officers and employees of an organization, it is required to refer to the purpose of its foundation and regulations concerning duties and penalties.
(8)The term "Government Official" in this Policy also includes "Foreign Public Official" which is defined by the Unfair Competition Prevention Act as follows:
i.Any person who engages in public services for a national or local foreign government
ii.Any person who engages in services for an agency affiliated with a foreign national government
iii.Any person who engages in services for a foreign public enterprise
iv.Any person who engages in public services for an International Organization
v.Any person who exercises a public function on behalf of a foreign national government, etc. as delegated
5. Prohibited Payment on Applicable Corruption Laws
Applicable Corruption Laws prohibit companies and their employees and representatives from giving, promising, offering, or authorizing payment of anything of value to any government official, etc. in order to obtain or keep business or to secure some other improper advantage. In essence, these laws prohibit the giving of anything of value to influence actions of a government official, etc. Prohibited payments include, but are not limited to, those aim to:
(1)Induce the recipient to award a contract to the Company;
(2)Obtain advantageous tax or customs treatment that would not otherwise be available to the Company; or
(3)Circumvent or cause non-enforcement of laws or regulations applicable to the Company.
6. Prohibition on Bribery
The prohibition on bribery applied to the giving of anything of value, not only money including providing business opportunities, favorable contracts, stock options, gifts, and entertainment. Such acts are barred even if:
(1)The benefit is for someone other than the party making the payment.
(2)The business sought is not with the government organizations.
(3)The payment does not in fact influence the government official's conduct.
(4)The government official initially suggested the payment.
7. Prohibition on Commercial Bribery
The UKBA and CUCPA specifically prohibit the offering or acceptance of corrupt payments and other advantages between private (non-government) persons and entities. Such conduct constitutes commercial bribery, Such conduct is prohibited by our Code of Business Conduct & Ethics.
8. Facilitating Payments
Facilitating (or expediting) payments (i.e. gratuity) (hereinafter referred to as "Facilitating payment") also are prohibited under this Policy. Facilitating Payments for Facilitation are small payments paid to lower-grade public officers in order to expedite or facilitate non-discretionary actions or services or typical government procedures.
As the examples from overseas, obtaining an ordinary license or business permit, processing government papers such as visas, providing police protection, providing telephone, power, or water service, or loading or unloading of cargo falls under this category.
Especially when you encounter a situation that you believe may require a facilitating payment to government official, etc. in overseas, contact Legal Compliance Department for consultation.
9. Prior Approval from Legal Compliance Department
(1) Duty of prior approval
Our Code of Business Conduct and Ethics and this Policy require employees to obtain approval from Legal Compliance Department before providing anything of value to a government official, etc.
(2) Exception
There is an exception to this general rule:
Payments are permissible without prior approval when an employee's safety is at issue, as for example when a payment must be made immediately to ensure safe passage out of a particularly dangerous geography. Employees should make whatever payment is necessary to protect their personal safety, and then, as reasonable, report the nature of the incident and related payment to Legal Compliance Department.
(3) Prior Consultation
Anti-bribery matters are not always clear and must often be addressed on a case-by-case basis.
In all situations where there is a question, employees should consult Legal Compliance Department.
10. Limited Exceptions
(1) Gifts, Meals, and Entertainment
It is not always easy to identify whether providing gifts, meals, and entertainment (or other hospitality) would be considered a corrupt act under Applicable Corruption Laws.
It may be permissible under such laws to provide modest gifts or a meal or other entertainment to a government official as a social amenity. Generally, gifts, meals, and entertainment are permissible, provided that:
i.There is no expectation that the gift, meal, or entertainment is given in exchange for any return favor or business advantage from the government organizations;
ii. The gift, meal, or entertainment is infrequent, reasonable, and proportionate in amount under the circumstances; and
iii. An approval is obtained from Legal Compliance Department beforehand.
When deciding whether a gift is appropriate, employees must take into account any past or future administrative matters that are within the recipient's realm of influence. The timing and context surrounding such gifting must be weighed in order to assess whether any particular gifting could objectively be perceived to be a bribe.
Before providing any gift, meal, or entertainment to a government official, always seek approval from Legal Compliance Department.
(2) Donations
It is sometimes permissible under Applicable Corruption Laws to make donations directly to government organizations (rather than to an individual government official) as part of a charitable effort or to promote goodwill through such actions as providing products to a government organization-sponsored celebration. Donations made to government organizations are permissible, provided that:
i.There is no expectation that the donation is given in exchange for any return favor or business advantage from the government organization;
ii.The donation is not made directly to an individual government official, and there is no indication that the donation will be redirected to an individual official's personal use; and
iii.The donation is infrequent and reasonable in amount under the circumstances.
Donations to private charities should not be made in the name of a government official, as a donation to an official's favorite charity could be viewed as a bribe.
In addition, the Company specifies those with approval authority over donations in the Regulations of Authority and Responsibility stipulated separately from this Policy. All donations made on behalf of the Company must follow the process specified in the Regulations of Authority and Responsibility. For more information, please refer to the Regulations of Authority and Responsibility.
(3) Political Contribution
The Company specifies those with approval authority over political contributions in the Regulations of Authority and Responsibility stipulated separately from this Policy. All political contributions made on behalf of the Company must follow the process specified in the Regulations of Authority and Responsibility. For more information, please refer to the Regulations of Authority and Responsibility.
(4) Hiring or Engaging Government Officials
The Company prohibits hiring of government officials as general rule.
11. Third Parties
(1) Prohibition of Unlawful Payment via Third Parties
Applicable Corruption Laws with which we must comply prohibit corrupt payments made directly by Company employees or indirectly through an agent or other intermediary such as a consultant acting for or on behalf of the Company (hereinafter referred to as "Third Party).
It is unlawful to make a payment of anything of value to any person, knowing that all or any portion of the payment will be offered, given, or promised to a government official or any other person for a corrupt purpose. The term "knowing" includes conscious disregard, deliberate ignorance, and willful blindness. In other words, the Company and individual employees may violate the FCPA if we have "reason to know" or "should have known" that an agent will bribe a government official, etc.
A company can be held criminally liable for bribes paid on its behalf by a third party in some country or area even if the company had no knowledge of the bribe.
(2) Careful Selection of Third Parties
Accordingly, the most important stem the Company can take to protect itself from liability for improper payments made by Third Parties is to choose carefully its business partners, including agents and consultants.
(3) Cases that may pose risks
Moreover, these "red flags" warrant further investigation when selecting or working with a Third Party. The following are examples of red flags:
i.The transaction involves a country known for corrupt payments.
ii.The third party has a close family, personal or professional relationship to a government official, etc. or relative of an official, etc.
iii.The third party objects to anti-corruption representations in Company agreements.
iv.The third party requests unusual contract terms or payment arrangements (e.g., payment in cash, payment in foreign currency, or payment in a third country).
v.Third party is suggested by a government official, etc (particularly one with discretionary authority over the business at issue).
vi.The third party's commission or fee exceeds fair and reasonable compensation for the work to be performed.
In all cases, whether or not any of these red flags are present, consult and seek approval from Legal Compliance Department before entering into any arrangement with a third party who will have a contact with a government official, etc. on behalf of the Company.
(4) Due Diligence
No relationship should be developed with a third party who will have substantive interaction with government officials, etc. on behalf of the Company without an inquiry into the third party's background, qualification and reputation.
When selecting a third party who will have substantive interaction with government officials, etc. on the Company's behalf, necessary information to thoroughly assess the background and reputation of the third party shall be obtained and confirm that:
i.The third party is not a government official or a company in which a government official has an interest, and
ii.The third party will become familiar with the Company's Code of Business Conduct & Ethics as well as Anti-Bribery Policy and certify that it will not engage in any improper practices that could expose the Company to liability or are otherwise inconsistent with Company business practices.
(5)Conclusion of Contract
All third party relationships that may involve contact with government officials, etc. must be identified in written contract including articles concerning compliance with all Applicable corruption Laws. When entering into a relation with a third party with interaction with government officials, etc., a written contract must be concluded including articles concerning compliance with Applicable corruption Laws. When creating a contract, please consult with Legal HQ.
Once an agent or consultant has been retained by the Company, the individual's activities and expenses must be monitored to ensure compliance with the Applicable Corruption Laws and Company Policy.
12. Recordkeeping
To keep record accurately and properly, all Company employees must:
(1)Follow the Company's Code of Business Conduct & Ethics, Company procedures, and Generally Accepted Accounting Principles;
(2)Accurately record all transactions, even when the transaction might violate Applicable Corruption Laws;
(3)Never agree to request for false invoices or for payment of expenses that are unusual, excessive, inadequately described, or otherwise raise questions under regulations, laws, and rules; and
(4)Never make any payments to anonymous (i.e., "numbered") accounts that are in the name of neither the payee nor an entity known to be controlled by the payee.
13. Auditing
Audit Section will conduct periodic audit of relevant Company operating units to ensure continued compliance to all Applicable Corruption Laws and this Policy.
14. Ethics & Compliance Reporting Hotline
Any observation of conducts that violate this Policy, please report it to Legal Compliance Department or call or send an e-mail to Ethics & Compliance Reporting Hotline. Suspected violations will be reviewed and investigated as appropriate and may lead to disciplinary action. Any retaliation for good faith reports will be violation of the Code of Business Conduct & Ethics. The Company prohibits any employees from taking measures that cause negative influence on the employment of the employee based on the fact that he/she made a good faith reports for his/her concern or cooperated with the investigation.
15.Supplementary Provisions
The policy is enacted and enforced effective April 1, 2017.
The policy is revised and enforced effective January 1, 2018.
Basic Policy for Procurement
We are procuring various goods and services so as to deliver products that are safe and reassuring for our customers. As an excellent company with dignity, we are committed to engaging in procurement activities in accordance with the following policies.
1.Our declaration for procurement activities
We are committed to comply with all applicable laws and engage in appropriate procurement activities in accordance with these policies, as well as the Code of Business Conduct and Ethics, regulations, handbook, and other rules of Coca-Cola Bottlers Japan group.
2.Fair and transparent trade practices
(1)We uphold fair, transparent, and free competition and will not engage in any unfair trade practices in our procurement such as those causing unreasonable disadvantage to our suppliers.
(2)We maintain equal and healthy relationships with our suppliers. In no event will we have any inappropriate relationships with our suppliers where we accept or demand benefits such as accepting gratuities or receiving entertainments or gifts that are beyond socially acceptable norms.
(3)We conduct appropriate education and guidance to prevent our executives and employees from engaging in unfair trade practices or having inappropriate relationships with suppliers.
3.Economic rationality
We select suppliers based on appropriate standards and through comprehensive evaluations with respect to product quality, price, delivery date, ability of maintaining stable supply, systems for complying with laws, reliability as a corporate entity, and other factors.
4.Appropriate control of information
We fully recognize the importance of confidential information and personal information obtained through procurement activities, and use and control such information in an appropriate manner in accordance with its category.
We engage in procurement activities with due consideration given to the global and regional environment.
6.Mutual prosperity
Our business cannot sustain its activities without cooperation and support from suppliers. Bearing in mind that our suppliers are our partners for growth, we are committed to furthering mutual prosperity and sustainability for growth.
7. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
We are procuring various goods and services so as to deliver products that are safe and reassuring for our customers. As an excellent company with dignity, we are committed to engaging in procurement activities in accordance with the following policies.
1.Our declaration for procurement activities
We are committed to comply with all applicable laws and engage in appropriate procurement activities in accordance with these policies, as well as the Code of Business Conduct and Ethics, regulations, handbook, and other rules of Coca-Cola Bottlers Japan group.
2.Fair and transparent trade practices
(1)We uphold fair, transparent, and free competition and will not engage in any unfair trade practices in our procurement such as those causing unreasonable disadvantage to our suppliers.
(2)We maintain equal and healthy relationships with our suppliers. In no event will we have any inappropriate relationships with our suppliers where we accept or demand benefits such as accepting gratuities or receiving entertainments or gifts that are beyond socially acceptable norms.
(3)We conduct appropriate education and guidance to prevent our executives and employees from engaging in unfair trade practices or having inappropriate relationships with suppliers.
3.Economic rationality
We select suppliers based on appropriate standards and through comprehensive evaluations with respect to product quality, price, delivery date, ability of maintaining stable supply, systems for complying with laws, reliability as a corporate entity, and other factors.
4.Appropriate control of information
We fully recognize the importance of confidential information and personal information obtained through procurement activities, and use and control such information in an appropriate manner in accordance with its category.
We engage in procurement activities with due consideration given to the global and regional environment.
6.Mutual prosperity
Our business cannot sustain its activities without cooperation and support from suppliers. Bearing in mind that our suppliers are our partners for growth, we are committed to furthering mutual prosperity and sustainability for growth.
7. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
1.Compliance with laws
Suppliers should comply with all applicable national and local laws, rules, regulations, and requirements in their manufacturing and distribution of the Company's products and supplies, as well as in their provision of services.
2. Freedom of association and the right to collective bargaining
Suppliers should respect the right of all their employees to decide at their will whether or not to join a labor union or to organize one in compliance with all applicable laws, free from fear of retaliation, threatening, or harassment. Constructive dialogues and negotiations in good faith should be conducted with representatives of a legitimate labor union chosen by the employees at their free will.
3. No child labor
Suppliers should comply with the minimum years of age for work as prescribed by applicable laws and regulations.
4. No forced labor or abusive treatment of workers
Suppliers should prohibit any physical abuse to its employees and all forms of forced labor and human trafficking.
5. Elimination of discrimination
Suppliers should eliminate discrimination both at the time of and during employment, and maintain a workplace free from physical or verbal harassment. Every effort should be made to ensure equal opportunity in the workplace and fairness in treatment.
6. Working hours and compensation
Suppliers should operate their business in compliance with all applicable laws governing wages, working hours, overtime hours, and welfare and benefits.
7. Providing safe and healthy working environment
Suppliers should provide a safe and healthy workplace where all people concerned feel secure at work. The workplace should be maintained to achieve high productivity where all risks of accidents, injuries, and any other aspects harmful for health are minimized.
8. Protection of environment
Suppliers should operate their business in such a way as to preserve and protect the environment. Comply with all applicable national and local environmental laws.
9. Doing business with integrity
Suppliers should comply with all applicable national and local laws, and should not do any acts of wrongdoing.
(1) No acts of inducing conflict of interests
Exercise caution not to allow its employees to enter into any relationships with an employee of the Company, which relationship may induce conflict of interests.
(2) Bribery
Do not provide or accept any gifts or entertainment in any business relationships, aiming to gain inappropriate benefits.
(3) Accurate records
Maintain accurate records of all matters in all transactions, ensure appropriate processing of accounts or other matters, and submit accurate invoices to the Company.
(4) Protection of information
Keep in confidence all confidential information exchanged in the business relationship with the Company. Ensure appropriate control and protection of personal information.
(5) Fair trade practices
Do not engage in any acts of impairing fair, transparent, and free trade practices.
(6) Protection of intellectual property rights
Respect all intellectual property rights, and do not infringe those owned by third parties.
(7) Quality of products
All products should satisfy the quality requirements agreed with the Company by way of contracts or otherwise, so as to provide safe products and services.
10. Handling of complaints and providing remedies
Suppliers should provide its employees with a mechanism that enables its employees to request for consultation or to make complaints without fear of retaliation, and ensures appropriate and timely countermeasures against any concerns raised by its employees.
11. Demonstrating compliance
Suppliers should be capable of, at the request of the Company, demonstrating its compliance with these Basic Policies for Suppliers.
12. Miscellaneous provisions
(1) The Company, THE COCA-COLA COMPANY, or COCA-COLA (JAPAN) COMPANY, LIMITED (hereinafter collectively referred to the "Company, etc."), or a third party designated by the Company, etc. may conduct audits to confirm the suppliers' compliance with these Basic Policies for Suppliers.
(2) The Company will have the right to require corrective actions to be taken by any supplier which violates these Basic Policies for Suppliers.
(3) The Company reserves the right to terminate all agreements and contracts with a supplier who fails to demonstrate its compliance with these Basic Policies for Suppliers.
(4) There may be a case where a separate agreement or contract with a supplier contains certain similar provision that is in greater detail than the provision in these policies. In such case, the provision of that agreement or contract will prevail.
(5) If the eight core conventions of the International Labor Organization (ILO) set higher labor standards than those set by local governments, the Suppliers should satisfy the standards of ILO.
(6) These Basic Policies for Suppliers are subject to change without notice in response to future amendments of applicable laws or regulations.
13. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
We offer opportunities for all employees to fully demonstrate their capabilities not depending on properties such as gender, age, presence of disabilities, human race or nationality while respecting diversity of each individual employee.
In addition, multi-faceted HR equipped with different culture, sense of value, ideas is our strength. We will generate new values by respecting various ideas and conducting constructive and positive discussions.
1.What do we mean by "Diversity and Inclusion"?
Diversity and inclusion in the workplace refers not only to the various "differences" that exist among the employees in an organization (=diversity), but also to accepting those "differences" and understanding and respecting the uniqueness of each individual (=inclusion).
We recognize that diversity can be seen from two aspects - diverse and multidimensional.
(1) Diverse aspect・・・External differences including gender, age, disability, race, nationality, etc.
(2) Multidimensional aspect・・・Internal differences including values, ways of thinking, experiences, etc.
2.Why is diversity and inclusion important to us?
(1) A workplace filled with diverse and multidimensional talent increases the employees' loyalty to the company and leads to acquisition of excellent talent.
(2) Higher loyalty to the company leads to increased employee motivation from which higher output can be expected.
(3) A corporation with diverse and multidimensional talent is filled with different thoughts and ideas and is strong when facing environmental changes.
(4) Active discussions among diverse and multidimensional talent generates new thoughts/ideas that lead to transformation and innovation.
(5) Diversity and inclusion-focused business leads to better economic activity, resulting in our ability to respond to the expectations of all our stakeholders.
3.Our basic approach to diversity and inclusion:
(1) We respect the diverse and multidimensional aspects of each of our employees.
(2) We provide opportunities for all our employees, not classified by any property of gender, age, disability, race, nationality, etc., to exert their abilities to the fullest, in our quest to create a work environment of active and diverse talent.
(3) By leveraging the various facets of our employees including values, ways of thinking, experiences, etc., we are committed to providing the best service to our stakeholders.
(4) We recognize the positive exchange of ideas between people of differing opinions as true, and such will be leveraged to generate transformation and innovation.
4.To realize diversity and inclusion:
(1) Led by top management, all officers and employees shall maintain a high level of awareness regarding diversity and inclusion, and each individual shall play an important role.
(2) We will create a structure to promote diversity and inclusion to develop plans including specific strategies and target setting (e.g. ratio of female employees and employment ratio of people with disabilities).
(3) Based on the plan, we will execute various programs and initiatives to spread diversity and inclusion.
(4) Target values and progress updates (assessments) will be disclosed internally/externally as required.
5.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
We will seek to maximize the value of a company in the group with growth-oriented position. To this end, we design a highly efficient organization capable in managing the company as if one entity united as a group from the perspective of overall optimization.
On top of that, we will set up a line of instructions, orders and reporting to enable speedy decision makings by clearly identifying roles of each team and giving reasonable responsibilities and authorities. We also periodically confirm progress of each organization's performances and make appropriate assessments.
1. Organizational structure
(1) Organizations are structured taking into account functions, roles, and regions so that the entire group's management targets are achieved in an effective and efficient way.
(2) Each organization is structured with its role and expected results clarified and in a way that allows speedy decision-making under predetermined authority.
(3) Organizations are structured in an easy-to-understand and simple manner to expedite decision-making and commanding.
2. Organization name
(1) Organization names should be easily understood by customers and employees, in principle.
3. Span of control
(1) In organization design, unnecessary organizations and posts are not established, being cognizant of the concept of "span of control." In setting up the standards, our actual conditions from the past and external benchmarks are referenced.
4. Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
1.Organizational conduct
(1) Each organization will operate under the system mindset, with clearly defined goals for its organization aligned with the (quantitative and qualitative) goals of CCBJI.
(2) Each organization will strive for speedy decision-making within the designated scope of authority, making use of business assets (people, things, money, information)for effective and efficient execution of the organization's strategies.
2.Chain of command/reporting line
(1) In principle, there will be a centralized chain of command/reporting line.
(2) The chain of command/reporting line will be made clear to allow for complete communication of instructions and command top down as well as reporting from the bottom up.
3.Information sharing
(1) In running our enterprise, the reality of our business shall be communicated quickly and accurately from top down, with open, constructive, customer-focused and fact-based communication among all organizations and tiers.
(2) To do so, the President and upper management will take the lead through proactive communication.
4.Performance management
(1) Performance in each organization shall be tracked based on achievement of performance targets (profit, NSR, sales (production) volume, share, etc.) and level of progress seen its initiatives (key initiatives in each organization defined to achieve business challenges).
5.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
We aim to be a company where employees can work their best with peace of mind and a sense of satisfaction and accomplishment to provide moments of happiness and refreshments to people and everyday life of local communities.
To this end, we set up and operate an HR system where employees are assessed equally and fairly and treated appropriately according to roles and performances in addition to setting up a safe and pleasant workplace environment.
We will also nurture professional employees who continue to take on challenges for innovations with passion by always thinking with users' point of view in order to further enhance values we offer to users (consumers and customers).
1.Human resource management policy
It shows our ideas on headcount plans, management and appropriate total labor costs to continue businesses extending to the future.
(1) Headcount plans, management
①We develop optimal mid- to long-term headcount plans based on macro analysis including trends of economic situations and future personnel mix to continue businesses extending to the future.
②We aim for highly efficient and productive structure by setting appropriate number of personnel (quota) based on productivity indicators connected to functional strategies.
③We identify duties that should be handled by regular employees or non-regular employees and optimize resources by setting quota by the regular employees and the non-regular employees.
(2) Total labor costs
We manage labor costs of employees and outsourcing personnel adopting values that can be tracked quantitatively (e.g. labor costs against sales revenue etc.) as management indicators for corporate labor costs in a bid to maintain the appropriate labor cost level, while allowing each function to develop total labor costs in principle.
2.Policy on HR system
It shows our ideas on a series of human resource management cycle to hire, assess, cultivate and treat "human resource". Note that we shall setup the HR system based on these basic ideas to be fair, just and consistent as CCBJI group.
(1) Employment
①We hire human resources who meet the criteria based on our headcount plans within the framework of employment after defining "HR we expect" as CCBJI group.
②In hiring, we focus on capabilities, character, experiences, potential and expertise and do not regard matters irrelevant to businesses such as nationality, human race or gender whatsoever.
③As a method for employment, we shall use various means (newly graduate employment, promotion to regular employees, mid-career employment and non-regular worker employment) in most efficient and effective ways.
(2) HR assessment
①Objectives of HR assessment shall be "to cultivate HR" and "to enhance performances" with key elements of assessment to be "results of work" and "actions expected for each role to raise the results".
②We shall connect the assessment results to remunerations (bonuses and basic salaries) and provide feedbacks to each person to lead to cultivation.
(3) HR development
①It shall be set in HR development policy.
(4) Internal ratings (grades)
①Internal ratings (grades) are determined according to work or roles currently assumed by each person and personal attributes such as nationality, human race, gender, age and years of service shall not be a determining factor. Moreover, the decision shall be made by holistically taking into account difficulty level of operations, performances, external trust, job satisfaction, level of impacts for customer/consumer satisfaction and the weight of responsibilities.
②For General positions, we shall setup a system of Internal ratings (grades) that allows reflection of learning level so that improvement of career level can be felt.
(5) Assignment and appointment
①We shall transfer personnel at appropriate and necessary timing to realize strategic assignment connected to cultivation of each individual employee and businesses.
②We shall assign right person in the right place according to adoptability by acknowledging diversity of each individual employee and comprehensively judging from results, motivation, capabilities and other elements.
③We shall determine a personnel transfer considering the person's career and personal circumstances as much as possible, avoiding it to be carried out on an ad hoc basis.
④We shall appoint a person to a post of managerial positions or higher from those the company determines to have capabilities to execute the roles, in principle.
(6) Remunerations
①We shall setup a remuneration system according to roles and results and treat fairly and justly.
②We shall setup a remuneration system that would lead to enhancement of motivation by frontline employees who offer value and services to customers.
③With a remuneration standard benchmarking Japanese and same industry corporations as a base, we shall aim for a level which allows us to maintain the competitive edge in gaining HR.
(7) Welfare benefits
①As lifestyles and sense of value diversity, we aim for setting up a system that leads to securing excellent HR and enhancing a sense of belonging in addition to improving job satisfaction by ensuring health and safety of employees and creating a workplace environment where employees can work with peace of mind.
②In particular, we shall extend initiatives on "activation of workplaces" that lead to "wellness of employees" and performance improvements as the base of management foundation.
③We shall build a well-balance system for a retirement allowance and a pension that support stability and security of old age, while incorporating impacts on corporate performances.
(8) Work hours, holidays, leave, work styles
①CCBJI group will work on the basic idea of "work-life balance"that supports diverse employees' lifestyles as a norm, in addition to securing peace of mind and health of employees through appropriate management of Work hours, holidays, leave, work styles.
②We shall drive activities to enable proper total work hours under the recognition that it's a corporate responsibility.
③We shall maintain appropriate level of specified work hours, considering functional characteristics of each company and department as well as common standards at the same time.
④We shall set the number of specified holidays and the calendar each year by placing customer-centricity as top priority, considering roles and functional characteristics of each company and the standard of other companies outside the group.
⑤We shall proactively consider flexible work styles that enable diverse ways to work, considering both "customer-centricity" and "work-life balance".
3.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
1.Human resource management policy
It shows our ideas on headcount plans, management and appropriate total labor costs to continue businesses extending to the future.
1.Basic concept for CCBJI Group's Human Resources Development Policy
(1)Under the acknowledgement that the factors that would provide impact onto the growth of any human resource is 70% business experiences, 20% OJT (guidance and mentorship from senior members), and 10% learning by classroom studying such as group training courses and self-enlightenment, training programs of efficient educational methods will be planned and executed to aim for developing human resources with the profile sought by CCBJI.
①Basic perspectives
i)Develop and execute customer-oriented employee development programs (by grades / jobs)
ii)Provide support for programs that ensure autonomous growth of the employees
iii)Improve job execution capabilities through OJT and Off-JT
iv)Develop leaders of the next generation in a planned manner in order to ensure sustainable growth
2.Roles in regard to human resources development
(1)The roles of the company, the senior members, and individual employees in regard to human resources development are as described below respectively;
i)In order to enable the employees to become closer to the "human resources the company seeks for", the company shall provide various educational / development opportunities to provide support for the employees' momentum for self-enlightenment in a proactive manner.
ii)The company shall provide opportunities for the employees to confirm their assumptions / expectations for their future career on a regular basis.
Additionally, the company shall provide various supports in order to specifically realize such assumptions / expectations each employee has.
②Senior members
i)Development of human resources is the most important job for the senior members, and they shall work upon developing the members via daily business.
ii)Senior members shall provide support so that each employee can obtain the knowledge required for executing their own jobs and so that each employee can improve his/her skills.
iii)In order to respect the intention and personality of each individual employee and therefore to ensure growth of their potentials to the highest extent, senior members shall become involved with the members in a proactive manner via daily business and improve their motivations.
③Individual employees
i)Employees shall work upon improving his/her own capabilities not only by attending to human resources development programs provided by the company or by receiving OJT from the senior members, but also my making an effort by themselves.
ii)Employees shall consider of their specific assumptions / expectations for their own future careers, and shall ensure daily effort in order to realize them.
3.Human resources development structure
(1)Human resources development shall be segregated into company-wide education and functional professional education, whereas each department in charge shall plan and execute the training programs in accordance with their own themes.
①Education system
i)Company-wide education
Educational opportunities will be provided for obtaining company-wide skills / knowledge in accordance with the growth / steps of each employee by utilizing training courses by the grade, training courses for selected members, training courses for applicants, and self-enlightenment programs, etc.
ii)Professional education
Educational opportunities will be provided in order to obtain the professional skills / knowledge that are required for executing businesses by utilizing group trainings and OJT, etc. within each Function.
②Educational method
i)Group training courses
Various programs which will enable improvement in knowledge / capabilities or the participants and therefore lead onto improvement in motivations shall be provided to the adequate participants in an appropriate timing.
Tools for enabling improvement in human resources development skills will be provided to the supervisors who are the key persons for OJT as part of the support for improving the OJT effect.
Environment shall be developed so that each employee can learn in accordance with his/her own environment, and various different learning opportunities shall be provided. Additionally, continuous efforts shall be made to encourage employees to work upon self-enlightenment.
4.Basic concept for human resources development trainings
(1)Educations in accordance with the career stage for each individual employee shall be provided. Practical trainings shall be provided so that the employees can obtain the knowledge and skills required for executing the jobs and for ensuring self-development in accordance with career stage and roles for each individual.
(2)The attitude of "proactive learning" of the employees shall be respected, and support will be provided for self-enlightenment. Various different programs will be provided for obtaining knowledge and skills in accordance with the jobs and roles for each individual.
(3)Fulfilling educational opportunities will be provided for the candidates of the leaders of next generation including Coca-Cola System's global program.
5.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.
1.Basic Policy
(1)We will observe occupational safety and health laws and regulations by local community and public institutions, requirements by KORE*, and other standards voluntarily set forth by the company.
*KORE is a unique management system on the four aspects of "quality", "food safety", "environment" and "occupational health and safety" over the entire life cycle of Coca-Cola products
(2)We will develop occupational safety and health plans and work on "the realization of safe and comfortable workplace" as a key theme in order to continuously improve occupational safety and health.
(3)We will foster and maintain all of our associates' occupational safety and health through enlightenment and educational activities.
(4)We will sustain good communication with local society and public institutions and strive for co-existence and co-prosperity.
We will make this Occupational Safety & Health Policy known to all associates and everyone working under our supervision and disclose it to the public.
2.Supplementary provision
The policy is enacted and enforced effective January 1, 2018.