Governance
Compliance, Fair Competition

Board oversight, supervision, and engagement have been hallmarks of Bridgestone’s ethics and compliance program for many years.

Overseen by the Board of Directors, and in collaboration with senior management in each region, Chief Compliance Officer (CCPO) and the Global Law Leadership Team are principally responsible for the design, administration, evaluation, and enhancement of Bridgestone’s global and regional ethics and compliance programs. The CCPO and Global Law Leadership Team are supported by Bridgestone’s Compliance and Fair Competition Working Group (WG) and regional teams of dedicated ethics and compliance professionals. Together, they work to identify annual and long-term regional and global ethics and compliance priorities and goals, confirm the progress of activities at the regional and global level, and report the results to senior management. Since its establishment, the WG has carefully evaluated the key elements and practices of highly effective corporate ethics and compliance programs and instituted short- and long-term strategies to foster a culture of ethics and compliance that is consistent with Bridgestone’s corporate values and principles.

It is the responsibility of the leaders, managers, and supervisors to abide by and enforce Bridgestone’s zero-tolerance policy related to bribery and corruption. Bridgestone regularly engages executive leaders, managers, and supervisors to keep them informed and educated about developments in the ethics and compliance program; ensure leaders, managers, and supervisors regularly talk about the importance of ethics and compliance; involve leaders in various training programs and communications; and help to ensure that ethics and compliance are at the center of all strategic plans and decisions. Periodic updates and reports are prepared and delivered by the regional ethics and compliance teams to their respective regional leadership teams and their respective Boards of Directors. Each region also has a Regional Ethics and Compliance Advisory Panel, consisting of senior leaders from different parts of the business, to help advise on the direction of the ethics and compliance program and ensure its effectiveness.

Bridgestone’s Chief Compliance Officer periodically reports to the Board of Directors’ Compliance Committee. Reports pertaining to global ethics and compliance activities are periodically made to the Board of Directors. The global compliance program, as well as the Code of Conduct (including its provisions related to the prohibition of all types of corruption, including bribery), is ultimately subject to the oversight of the Board of Directors.

While the ultimate responsibility for building and maintaining an effective ethics and compliance program starts with senior management, every employee must also own this responsibility. With that in mind, in addition to fostering regular and open communication with and among senior leadership on compliance improvement processes, Bridgestone’s ethics and compliance program focuses on active engagement with employees at all levels (including managers and supervisors) within the organization. It aims to emphasize their responsibility to perform their roles with integrity and employ ethical business practices at all times. Bridgestone’s ethics and compliance program uses this practical, risk-based approach to promote a true culture of ethics and compliance throughout the business.

Bridgestone takes a risk-based approach in designing the ethics and compliance program and promotes a true culture of compliance throughout its business. Bridgestone regularly assesses how its operations are changing, as well as the evolving risks it faces, and takes appropriate actions to address and mitigate such risks. The following briefly highlights how Bridgestone manages risks relating to bribery, corruption, and antitrust issues.

As a global company, Bridgestone operates in countries with a wide range of risk profiles, making anti-bribery a central focus of its global compliance program, along with regional compliance education efforts. In 2023, Bridgestone updated its Global Anti-Bribery Policy, which was launched in 2020, to reinforce its expectations of all employees and third-parties acting on its behalf and to realize the Bridgestone E8 Commitment. This policy reinforces Bridgestone’s longstanding stance against bribery and corruption and represents another significant milestone toward achieving its long-term goal of having an effective global ethics and compliance program. This policy builds on the Code of Conduct and conveys Bridgestone's comprehensive stance against all forms of corruption, addressing topics such as bribery, facilitating payments, gifts and entertainment, dealings with third parties, books and records, and political contributions. The policy applies to employees of Group Companies around the world, including joint ventures that it controls, and third parties acting on Bridgestone’s behalf. Where Bridgestone participates in but does not control a joint-venture relationship, it encourages partners to adopt similar requirements and abide by the principles of this policy in their own operations.

As further described below, Bridgestone also recognizes the bribery risks that exist in working with third parties and conducts due diligence on the third parties it engages. Bridgestone has a robust compliance due diligence program, supported by a third-party screening tool, to identify bribery and trade-compliance risks presented by third parties with which Bridgestone works.
The Global Anti-Bribery Policy and the tool help to significantly strengthen Bridgestone’s global anti-bribery program.

Bridgestone’s commitment to ethics and compliance extends to third parties with whom it does business. Accordingly, a variety of third parties that Bridgestone engages and works with are subject to the expectations of the Code of Conduct and the Global Anti-Bribery Policy, including Bridgestone’s comprehensive prohibition of bribery and corruption described above.

Bridgestone’s suppliers are also subject to the requirements of the Global Sustainable Procurement Policy. The policy’s requirements include the strict prohibition of all forms of corruption, bribery, extortion, and embezzlement, as well as a requirement to comply with applicable laws, including those related to competition. As to version 3.0, revised and published in January 2024, Bridgestone established the goal and KPI of “100% of all Level 1 and 2 suppliers will have acknowledged the revised Global Sustainable Procurement Policy.” (As of March 31, 2025, 74% of Level 1 and 2 suppliers had done so.)
Please refer to the “Procurement” section for detailed information.

Bridgestone also seeks to mitigate third-party risks by conducting appropriate due diligence. This includes communicating its Global Anti-Bribery Policy and assessing risks posed by each third party. The risk-based approach – including Bridgestone’s assessment of the relevant risks and procedures – is designed to ensure that high-risk third parties are subject to enhanced due diligence and ongoing monitoring. This includes intermediaries (contractors and agents) who have dealings with government entities and officials and those who operate in high-risk locations for bribery, money laundering, or other forms of corruption. This ongoing due diligence helps inform Bridgestone’s decisions about which third parties to engage and how to manage and oversee such relationships. If this due diligence or ongoing monitoring reveals any signs of irregularity, Bridgestone will take appropriate action, including but not limited to terminating business with the third party.

To further reinforce the compliance due diligence program and mitigate anti-bribery risks, Bridgestone started a review of all high-risk intermediaries in 2023 with the aim of ensuring that proper controls are in place when engaging with these intermediaries. As of December 31, 2024, 95% of Bridgestone's high-risk intermediaries have been reviewed.

Bridgestone did not pay any fines, penalties, or settlements in connection with corruption-related activities in 2024.

In addition to the guidance and requirements detailed in the Code of Conduct, all regions currently have their own antitrust policies in place for their respective regions and regularly evaluate how to continuously improve and strengthen their antitrust programs. This is a topic Bridgestone takes seriously and makes sure that all new and existing employees understand the requirements.

The departments responsible for compliance in each region work closely with other regional departments — including sales, marketing, human resources, procurement, finance, and internal audit — to understand changes in the marketplace, workplace, and society in general. They also ensure that overall operations, including global and regional ethics and compliance programs, evolve in parallel. Because the global and regional ethics and compliance programs are intricately linked to all aspects of Bridgestone’s business and operations, the global and regional ethics and compliance functions proactively seek dialogue and opportunities to ensure that the programs are supportive and reflective of the Mid Term Business Plan. This includes providing ongoing legal and compliance advice on antitrust laws and processes, and identifying employees who are most likely to face antitrust risks and provide training (which may be live, e-learning, or other types of training) for those employees.

The global and regional ethics and compliance programs also regularly assess, review, and update (as needed) Bridgestone’s existing processes and standards to ensure they are well designed and effective to ensure compliance with applicable antitrust laws.

As a global organization, Bridgestone ensures the Code of Conduct is easy to understand. Therefore, it has been published in multiple languages throughout the regions in which Bridgestone does business. It is available to employees and the general public through global and regional corporate websites. It is also accessible to employees through Bridgestone’s regional intranet sites.

The Code of Conduct is supplemented by global, regional, and local policies, which are available to employees through a variety of ways, including Bridgestone’s corporate intranet sites, and some policies (such as the Global Anti-Bribery Policy) are publicly available on Bridgestone’s website. These policies are consistent with the Code of Conduct and provide detailed and practical guidance on key topics, taking into consideration the requirements of local legislation. Each region creates additional processes or procedures (for example, processes and approval requirements relating to gifts, meals, entertainment, and travel involving third parties) to help ensure the correct application and interpretation of the Code of Conduct and other global policies.

In the spirit of continuous improvement, Bridgestone regularly evaluates the existing policies to address new compliance risks and to identify opportunities where it would make sense to consolidate regional or local policies into global policies.

Regardless of how an allegation of misconduct is raised, each report is thoroughly investigated by Bridgestone’s Compliance team or other relevant departments (such as the Human Resources Department or the Internal Audit Department) depending on the subject matter. Each region has detailed investigation procedures and protocols to help ensure the quality and consistency of investigations. Each region has developed and tracks certain data and metrics to identify risk areas and trends as well as assess the effectiveness of internal investigations. The results are provided regularly to the Board of Directors and each significant subsidiary around the world.

Substantiated or partially substantiated reports of wrongdoing may lead to disciplinary or corrective actions, including up to termination of employment. Regardless of the investigation outcome, process improvement opportunities may be identified to create a more effective control environment.