Anti-Bribery and Anti-Corruption Policy

1. What is this policy?

MUFG Pension & Market Services is committed to complying with all applicable laws and regulations and conducting our business with the highest standards of ethics and integrity. MUFG Pension & Market Services does not tolerate bribery and corruption. The Anti-Bribery and Anti-Corruption Policy (the Policy) supports the Code of Conduct and Ethics that sets the standards for the way we work.

The Policy sets out the requirements, responsibilities and approach for the governance, prevention, deterrence, detection, investigation and reporting of instances of bribery and corruption involving employees, consultants and/or any other third parties in a business relationship with MUFG Pension & Market Services, including members, investors, customers, clients and vendors.

Words in bold have the meaning stated in ‘Section 8. Definitions’ and appear in bold when first used.

2. Why do we need this policy?

Bribery and Corruption have a detrimental impact on society and the integrity of the markets. MUFG Pension & Market Services aims to act with the highest standard of integrity and honesty in all it does and is committed to drive an effective anti-bribery culture.

Adherence to anti-bribery and anti-corruption best practice governance, controls and compliance is essential to our business principles and is consistent with our values.

The Policy:

• Confirms we will comply at all times with legislation in the jurisdictions where it operates
• Prohibits the promising, offering, giving, solicitation or receiving of bribes and anything of value, directly or indirectly through third parties, including public officials, if improperly intended to influence a course of action or obtain an advantage
• Prohibits falsifying or concealing any records or accounts that relate to the business or that of its customers, suppliers and other business partners
• Confirms that facilitation payments, kickbacks and secret commissions are not acceptable business practices
• Enables staff to understand their roles and responsibilities in the identification, prevention, detection and escalation of bribery and corruption incidents
• Reinforces that we will terminate a contractual relationship with a third party if they are found to have been involved in bribery and corruption activities
• Prohibits all donations to political parties and campaigns, directly and indirectly, and requires approval for attendance at selected events
• Seeks to protect our reputation.

3. Who does the policy apply to?

This Policy applies to MUFG Pension & Market Services and its subsidiaries directors, employees, contractors and all other people who represent MUFG Pension & Market Services and its subsidiaries (Our People) globally.

Compliance with the Policy is mandatory, and no exceptions are allowed. In jurisdictions where the local legislative and regulatory requirements exceed the requirements set out in this Policy, the businesses operating those jurisdictions must comply with such higher standard. The additional requirements must be documented in their jurisdictional standards, procedures or other documentations, supplementing this Policy.

4. How to comply with this policy?

4.1 Managing Bribery and Corruption Risks

MUFG Pension & Market Services has adopted a risk-based approach to managing bribery and corruption which recognises that the threat posed varies across the jurisdictions and business sectors in which we operate, and the nature of the business we transact.

In addition to the key principles and prohibitions set out in section 2, other key measures include, but not limited to:

• Periodic risk assessments that include bribery and corruption risk, that consider the risk exposure associated with the business operation and jurisdictions MUFG Pension & Market Services operates in, and the control environment. 
• Due diligence is conducted to confirm there is no concern of bribery before entering into a business relationship with a third party. 
• Before onboarding a vendor, it needs to be confirmed that the vendor has established anti-bribery system/process in place. 
• As part of recruitment process, employment screening is conducted on all prospective employees and directors to ensure their identity, honesty and integrity. Refer to the MUFG Pension & Market Services Employment Screening Policy for details.
• The MUFG Pension & Market Services Conflicts of Interest Policy prohibits the giving or accepting of gifts and hospitality that may improperly influence them or others, including public officials. Additionally, any exchange of gifts and hospitality with public officials must adhere to the relevant local laws. Our People must comply with the Conflicts of Interest Policy, including the approval and record keeping requirements within the policy, when giving or accepting gifts or hospitality, and take particular care when it involves a public official. 
• The MUFG Pension & Market Services Whistleblower Policy encourages and supports the reporting of illegal or unethical conduct including bribery and corruption. 

4.2 Training and access to the Policy

All directors, employees and contractors are required to undergo training on the Code of Conduct and Ethics, which includes bribery and corruption content, at the beginning of their employment and on an annual basis thereafter. 

The Policy is available on our public website, intranet and on request from the Risk and Compliance team.

5. Roles & Responsibilities

5.1 What does MUFG Pension & Market Services expect from third parties? 

Third parties, such as vendors, agents, or anyone engaged by them to act for or on behalf of the MUFG Pension & Market Services must not:

• Offer, give, request, agree to receive, or accept a bribe, or
• Do anything to circumvent controls in place to deter, prevent or detect bribery.
• Third parties are expected to have controls and processes in place that are:
• Proportionate to the bribery risk
• Communicated to all relevant parties, and
• Reviewed regularly and reflect current legislation and best practice. 

To the extent permitted under applicable law and in accordance with contractual requirements, third parties must, as soon as reasonably practicable, notify us if a person acting on their or our behalf is suspected of bribery or corrupt practices or prosecuted, charged with or convicted of any Bribery or Corruption related offences.

6. Policy Monitoring and Reporting

Bribery and corruption breaches may be reported through a range of channels, including risk events and Suspicious Matters Reporting (via the GRC system), direct managers, divisional risk and compliance teams, the human resources team and the ELT.

In order to facilitate the process for reporting of bribery and corruption and any other disclosures of serious concerns, we have also established a Whistleblower Policy and has implemented various channels (internal and external) through which employees and other eligible persons can report suspected or actual occurrence of bribery and/or corruption, incidents anonymously if they choose.

Any occurrence of bribery or corruption, or an event which could lead to such occurrence, needs to l be reported by the Chief Risk Officer, in consultation with the Chair of the Board Risk & Compliance Committee, to the police and, if appropriate, other appropriate regulatory authorities. 

Any material breaches of the Policy will be reported to the Board or the Board Risk & Compliance Committee.

7. Non-Compliance 

Non-compliance with the Policy will be dealt with in accordance with established administrative or disciplinary procedures which may result in disciplinary action, including termination of employment or engagement.

The individuals who breached the Policy may also face civil or criminal actions. MUFG Pension & Market Services may be obligated to report to the regulatory authorities of the jurisdiction when such conduct is identified.

There may also be serious implications for MUFG Pension & Market Services, leading to enforcement actions, fines, criminal proceedings, and reputational damage.

8. Related Documents and Sources 

This Policy should be read in conjunction with:

• MUFG Pension & Market Services Code of Conduct & Ethics
• MUFG Pension & Market Services Employment Screening Policy
• MUFG Pension & Market Services Conflicts of Interest Policy (including Gifts & Hospitality)
• MUFG Pension & Market Services Anti-Money Laundering and Counter-Terrorism Financing, Sanctions and Fraud Prevention Policy
• MUFG Pension & Market Services Risk Events Management Policy
• MUFG Pension & Market Services Whistleblower Policy
• MUFG Pension & Market Services Regulatory Interaction Policy

Related external sources include:

9. Definitions

[Last updated: August 2025]