Promotion and structure of compliance management

The Group has established a “Code of Business Ethics” to ensure sound development and corporate ethics, and to maintain and promote compliance management.

We have also established a “Compliance Committee” (integrated into the Risk Management Committee from FY2022) to deliberate on various measures to promote compliance management. In the unlikely event of a serious compliance violation, the Committee will make recommendations on how to correct the situation and prevent its recurrence.
The Compliance Committee is chaired by the President in accordance with the Committee’s Regulations, and meets once a month in principle, subject to confidentiality obligations. In FY2021, the Compliance Committee met on a monthly basis, or 12 times in total, to report on the operation of the Business Ethics Hotline System and compliance or risk-related news.

Assignment of compliance officers

“Compliance officers,” who play a central role in raising awareness of compliance, are assigned to each department within the company and each Group company. The person in charge prepares a “Compliance Awareness Implementation Plan” for each fiscal year and conducts awareness-raising activities. A plenary meeting is held to exchange opinions on the progress of projects.

Implementation of compliance training

Various training programs are conducted on an ongoing basis to instill compliance awareness among all officers and employees of the Group. In preparation for the mandatory response to power harassment in FY2021, we newly incorporated training to improve the response capability of the harassment consultation desk and seminars on how to respond to cyber-attacks, which have been on the rise in recent years, into our training programs.
Furthermore, every October is designated as “Compliance Enhancement Month” to strengthen compliance efforts by displaying educational posters and implementing other measures.
In addition, to firmly establish the spirit of the “Code of Business Ethics,” we use the “Compliance Manual,” which provides practical guidelines for the actions to be taken by each and every officer and employee of the Group, and strive to disseminate the philosophy of compliance management and to block any relationship with anti-social forces.

Whistleblower system

As a system for the early detection and correction of legal and ethical problems of the Company and Group companies, we have established a “Business Ethics Hotline System” to receive internal reports and consultations from officers and employees.
This system is designed to accept whistleblower reports and questions and consultations regarding legal and ethical issues in business activities, with 27 cases reported in FY2021 (14 cases in FY2020).
The system is evaluated as a self-cleansing mechanism that prevents “individual employees from dealing with their problems alone” and allows “the company to detect and correct problems at an early stage,” as well as functioning as a “deterrent to illegal activities.”
In addition, in light of the revised Whistleblower Protection Act to be enforced in June 2022, the “Business Ethics Hotline System Regulations” stipulate that all officers and employees shall neither treat informants in a disadvantageous or unfair manner nor engage in retaliatory or discriminatory actions against informants. In addition, the system operation status is regularly reported at the Risk Management Committee and the Board of Directors meetings. Anonymous consultation and reporting are also possible, and a consultation desk has been set up at an outside law firm in addition to the company’s own consultation desk.

Establishment of basic policy on anti-corruption

In April 2022, the Company declared its commitment to preventing corrupt practices and established the following basic policy to realize this commitment.

Introduction of clauses to exclude organized crime groups

The “Guidelines for Enterprises to Prevent Damage Caused by Antisocial Forces” established by the government require companies to further promote efforts to sever ties with anti-social forces, including organized crime groups.
In response to this, we started introducing clauses in FY2008 for the exclusion of organized crime groups in contracts and other documents concluded by each department.