English

11/18

11• The Intermediary is, or has close family or business ties • The Intermediary has been recommended by a Government Official, particularly one with discretionary authority over the business at hand;• The Intermediary recommended by our business partner does not have meaningful expertise or prior experience in the field of work for which he is recommended;• The Intermediary requests a fee/commission that is • The Intermediary requests unusual payment terms, such as an up-front lump sum payment, payment to an account in another party’s name, payment in a currency that has no relationship to the transaction, or payment in a third country, especially if it is a country with little banking transparency;• The Intermediary suggests that a particular amount of money may be necessary to obtain business or “close the deal”;• The Intermediary requests reimbursement of extraordinary, • The due diligence notes the presence of unexplained sub-contractors or vendors that the Intermediary proposes to retain to assist with interactions with the government.Examples of “red flags” include the following:to, a Government Official;excessive or to be paid in cash;poorly-documented, or last-minute expenses; andAppropriate commitments and targeted contractual provisions should be used to help reduce identified risks, including any risks or other relevant information discovered in due diligence findings, and the contractual provisions should be regularly monitored to ensure the Intermediary is acting in accordance with the contract. Additional measures and safeguards, including compliance certifications and training, may also be utilized. Your obligations of due diligence do not end once an Intermediary is selected and engaged. You should carefully explain our compliance expectations, continuously monitor the Intermediary’s activities and stay alert to “red flags” to ensure continued compliance throughout the engagement.Due diligence is also critical in the context of new business endeavors, such as acquisitions and joint ventures. Before entering into any such endeavors, consult with the Law Department for advice on appropriate due diligence and safeguards to mitigate bribery risks.To learn more about Bridgestone’s anti-bribery due diligence process, please visit the compliance intranet site for your location or contact the Law Department. If you are in any doubt about how this Policy and our anti-bribery due diligence program applies to a particular business endeavor or the engagement of any particular third party, or if you have any concerns about a prospective or existing Intermediary, contact the Law Department for assistance.Bridgestone Global Anti-Bribery Policy“RED FLAG” EXAMPLES