INTRODUCTION
The JVC KENWOOD GROUP Compliance Code of Conduct establishes the common values and ethics by which all Zetron Officers and Employees, as members of a subsidiary company of the JVC Kenwood Group, are to conduct themselves.  This Anti-Bribery and Corruption policy is an addition or extension to the Code, and together they outline the values and standards of behavior we expect of everyone engaged by us when conducting business on our behalf.

ZETRON POLICY STATEMENT ON BRIBERY AND CORRUPTION
Zetron is committed to operating at all times under the highest ethical standards and conducting ourselves in a socially conscious manner in our country and in others.  Zetron expects its employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings, to comply with all legal and regulatory requirements, both domestically and wherever they are conducting business, and to exercise appropriate standards of professionalism and ethical conduct in all activities.  Zetron expects the same approach to doing business from its business partners, contractors, and suppliers.

Zetron will not tolerate bribery or corruption in any form and has established a “zero tolerance” approach to any breach of this policy. This means that no one on our behalf will seek, accept, or give an inappropriate or illegal  bribe, “facilitation” payment, kickback or other improper or illegal payment.

To ensure that Zetron meets this commitment, we will take appropriate steps to ensure that:

• We do not, directly or indirectly, offer, promise, give, accept or demand a bribe or other undue advantage (including excessive gifts and hospitality) in order to obtain or retain business, or gain any other improper advantage.
• We do not offer nor give in to demands to make illicit or illegal payments to agents, public officials (at any level), or the employees of business partners or any others that we do business with.
• We engage, pay and/or reimburse agents and other third parties only for legitimate services.
• We promote employee awareness of, and compliance with, company policies against bribery and corruption through appropriate dissemination of our own procedures (including disciplinary procedures), policies, and training programs upon joining the company and periodically thereafter.
• We employ management control systems that discourage bribery and corruption, and apply financial and tax accounting and auditing practices that prevent the establishment of “off the books” secret accounts or the creation of documents which do not properly and fairly record the transactions to which they relate.
• We do not make illegal or inappropriate contributions to candidates for public office or to political parties or to other political organizations
• We raise awareness of the need to combat bribery and corruption with our business partners by publication of this Policy and, where appropriate, relevant contractual provisions and support initiatives designed to reduce the risk of bribery and corruption.
• We operate with appropriate transparency in all our business dealings.