Anti-Corruption 2026

JAPAN Trends and Developments Contributed by: Masayuki Atsumi and Yuhei Sakao, Miura & Partners

• audits; and • review by management.

If executives and employees fully understand the laws and regulations on bribery, including the severity of the penalties and the reputational damage to the com - pany if bribery is discovered, they would realise how unprofitable and shortsighted it is to engage in bribery to gain immediate profit. Furthermore, if executives knew that involvement in bribery would severely dam- age them and their companies, they would be more likely to steadfastly refuse to become involved, even under pressure from public officials. As disseminating accurate legal information and ethical standards to all executives and employees is not easy, it is impor - tant for management to continuously communicate messages and conduct regular education and training programmes. The authors hope that this report will be of help in this regard.

Although the Guidelines were prepared from the per - spective of preventing bribery of foreign public offi - cials, the basic points and suggestions presented therein are also very useful for preventing bribery of domestic public officials in Japan. The formulation of basic policies and internal rules and educational activities is highly effective in preventing bribery of both domestic and foreign public officials. Conclusion Corruption continues to occur across countries and industries, and Japanese companies are not immune to the risk of bribery. The authors believe that bribery cases have not been eliminated, not only because of the greed of individuals or corporations aiming to gain business advantages and deficiencies in internal controls and governance, but also due to the lack of sufficient legal knowledge and integrity among executives and employees.

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