Compliance Promotion

Our Basic Policy

The Asahi Group established the Asahi Group Code of Conduct in January 2019 as a means of achieving the Asahi Group Philosophy (AGP), which applies across the Group. In September 2023, to further the penetration of the Code of Conduct throughout the Group, the Asahi Group Code of Conduct was refreshed and localized in 24 languages, accessible to officers and employees of all Group companies, including those overseas.

We understand compliance to mean acting in a way that society expects a corporation to act. This includes observing laws and public regulations, company regulations, and other rules in addition to social norms and the like, or in other words, never betraying the relationship of trust with stakeholders. As such, the Asahi Group Code of Conduct defines the specific actions that all officers and employees should take, and by making all personnel fully aware of the Code of Conduct we are working to ensure that they act with compliance as their top priority.

The Board of Directors is responsible for monitoring compliance with the Code of Conduct. The establishment and/or revision (excluding minor changes) of the Code of Conduct shall be resolved and determined by the Board of Directors. In order to maintain a high level of compliance initiatives, we will continue to evaluate and verify the effectiveness of the Code of Conduct and other initiatives regularly and make improvements as necessary.

The Asahi Group Code of Conduct

Compliance Promotion Systems

The Asahi Group established the Asahi Group Ethics/Compliance Policies to promote compliance management. Based on the Policies, we clarify our internal system and operation and promote fair and highly transparent business activities founded on compliance in the broad sense of the term, going beyond the observance of laws and regulations.

The Asahi Group established its Compliance Committee as the highest-order organ to deliberate on compliance. The Committee consists of Executive Officers, the Head of Legal Section, and other persons of Asahi Group Holdings appointed separately by the Chairperson of the Committee. It monitors the occurrence of compliance issues and the status of compliance promotion activities at the Asahi Group, and works to improve awareness of the Asahi Group Code of Conduct and operation of the whistleblowing system “Speak Up” to raise the efficacy of compliance promotion activities.

Furthermore, the chief executives of all of Asahi Group's operating companies are responsible for observing and promoting compliance with the Asahi Group Code of Conduct, while the legal departments of the Group’s operating companies in both Japan and overseas cooperate with one another to structure the Group’s compliance promotion system.

Efforts to Prevent Corruption

In response to tightening restrictions on bribery^※ in countries around the world, the Asahi Group established the Asahi Group Anti-Bribery Principles, which applies to all of the Group’s officers and employees, and is making Group-wide efforts to build a system to prevent corruption.

The Asahi Group Anti-Bribery Principles prohibits such acts, including the direct and indirect provision or receipt of bribery and the provision of facility payments. We require all of Asahi Group companies’ business partners and intermediaries including legal agents to adhere to the Principles, prohibit acts of corruption and ensure their full awareness in cases of acquisitions, mergers, joint ventures, and other similar arrangements, we will conduct an assessment of the counterparty in advance in accordance with the risk levels of corruption. Based on the results of the above risk assessment, for operations assessed as high risk, we implement initiatives to ensure compliance in accordance with the laws and regulations of each country in which we do business, as well as our internal rules, and communicate these initiatives to our employees.

To educate our employees on this issue, we conduct training on the prevention of corruption.

The Board of Directors is responsible for monitoring compliance with the Asahi Group Anti-Bribery Principles, while the Compliance Committee oversees compliance with the Asahi Group Code of Conduct, which includes stipulations on the prevention of such corrupt acts as bribing public officials, providing entertainment or gifts, making inappropriate donations, associating with organized crime elements, or being involved in money laundering. The Compliance Committee reports its findings to the Board of Directors.

• The terms, “Bribe-giving”, “Bribe-taking” and “Bribery” used in the Asahi Group Anti-Bribery Principles are defined as follows:

• "Bribe-giving" means providing, proposing, or promising monetary or other benefits aiming to cause an act or omission by any party in his official capacity such that another would receive an improper interest in connection with business.
• "bribe-taking" means receiving, requesting or being promised to receive monetary or other benefits of personal interest or interest of a third party with the aim to cause an act or omission by any party in his official capacity such that another would receive an improper advantage in connection with business.
• "Bribery" means Bribe-giving and Bribe-taking.

Violations of the Asahi Group Anti-Bribery Principles within the Asahi Group in 2025

The Asahi Group Anti-Bribery Principles

Implementation of Compliance Training

With the aim of enhancing the level of compliance, the Asahi Group develops and conducts group-wide training and awareness activities, such as the Asahi Group Code of Conduct carried out under the leadership of the head office, and implementation of ethics and compliance training with optimized content and method tailored for group companies.

Overview of Our Compliance Training

We generally conduct annual training on the Asahi Group Code of Conduct for all Asahi Group employees, including those overseas once a year. Further, on-demand training is also conducted on as needed basis, in accordance with the circumstances of each region, country, and business entity.

Monitoring System

Internal Audit

Asahi Group Holdings checks compliance with legal and company rules in internal audits conducted by our Internal Audit Section every year.

Compliance Survey

The Asahi Group conducts an anonymous global engagement, ethics & compliance survey once a year. The aim is to verify the level of awareness of the Asahi Group Code of Conduct, identify the awareness of and intention to use “Speak Up” as well as the compliance risks present, then apply the findings to making improvements.

Whistleblowing System

The Asahi Group has been operating “Speak Up”, a global whistleblowing system which serves as a global compliance framework in accordance with the Asahi Group Code of Conduct, and also functions as a grievance mechanism aligned with the UNGPs. By introducing “Speak Up”, we aim to promptly identify compliance issues and human rights violations associated with our corporate activities, ensuring early detection and correction of issues, as well as swift relief for victims. This system allows all stakeholders of the Asahi Group, including employees, business partners and communities, to report any suspected misconduct in relation to the Asahi Group through the channel below. Suspected misconduct includes breaches of the Asahi Group Code of Conduct or the law and human rights violations, and a report can be made anonymously, at any time 24 hours/365 days, in various local languages of the areas in which we operate, using the online form or telephone hotlines.

Group-wide reporting channel “Speak Up”
Web: asahigroup.ethicspoint.com
Mobile： asahigroupmobile.ethicspoint.com

All reported cases are duly considered and investigated as necessary by the Asahi Group’s investigation team. If the case is substantiated as a result of investigations, we take appropriate remedial actions, including disciplinary action and termination of employment, in accordance with the internal rules, such as “Rules of Employment”. Not only in cases of violations of laws or internal rules, but also in cases that do not constitute violations, we take appropriate, case‑specific actions, including policy/process review and training, as necessary to improve the situation. We thereafter provide feedback to the reporter.
Details on the operation and usage of this system are set forth in the "Asahi Speak Up Policy," which also sets the ground for ensuring the confidentiality of reports and protecting those who make reports against any disadvantageous treatment. The principles to ensure that all investigations are conducted in a fair, neutral and objective manner are outlined in the “Asahi Group Basic Principles on Whistleblowing Investigations”.

Asahi Speak Up Policy
Asahi Group Basic Principles on Whistleblowing Investigations
Overview of Speak Up

The Asahi Group has been working to raise awareness of the “Speak Up” system both internally and externally by conducting regular training sessions on the system using videos and other forms of media, promotional campaigns, messages from management, such as our Group CEO, as well as explanations for our business partners.
In addition to the above, each Asahi Group company may have its own whistleblowing channel, as necessary, and reports submitted through such channels are also handled appropriately.

Number of Whistleblowing Reports

Since introducing the global whistleblowing system “Speak Up” in fiscal year 2024, we have been disclosing the total number of reports across the entire Asahi Group, both domestically and internationally, broken down by categories.

• For the period 2020-2023, only the number of reports in Japan is shown.