Compliance
Advocacy for 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. In the unlikely event of a serious compliance violation, the Risk Management Committee, chaired by the President and COO, will formulate measures on how to correct the situation and prevent its recurrence.
In principle, the Risk Management Committee meets once a month, subject to confidentiality obligations. In FY2023, the meeting was held 12 times in total to report on the operation of the Business Ethics Hotline System and compliance/risk-related news reports, and the management team shared the contents of these reports.
System for promoting compliance
The Company has established a Risk Management Division as a dedicated department in charge of compliance, and has appointed a Corporate Officer to be in charge. In addition, we have appointed Compliance Risk Owners who are responsible for promoting compliance risk reduction across the entire Group, as well as Compliance Officers in each department and Group company to raise awareness in the workplace.
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. For FY2023, a compliance training program was conducted with content appropriate to the position of officers and below. Furthermore, every October is designated as Compliance Enhancement Month to strengthen compliance efforts by displaying educational posters and carrying out other measures. In addition, to firmly entrench the spirit of the Code of Business Ethics, we have created a Compliance Handbook that provides practical guidelines for each and every officer and employee of the Group on how to act, and a Compliance Card for employees to ask themselves about their own decisions and actions from the perspective of compliance. The Compliance Card is distributed to all officers and employees of the Group.Through these initiatives, we are working to implement compliance education.
Contents of the Compliance Handbook.
Corporate philosophy, policies, etc.
・Corporate philosophy ・Group management policy
・Code of business ethics ・Basic policy on anti-corruption
・Nankai Group Human Rights Policy ・Corporate Ethics Hotline
Good working environment
・Prohibition of human rights violations and discriminatory treatment
・Creation of a proper working environment
・Prohibition of sexual harassment ・Prohibition of power harassment
・Prohibition of maternity (paternity) harassment
Fair business practices
・Creating a workplace where fraud is unlikely to occur
・Customer safety first
・Timely and appropriate information disclosure
・Appropriate reporting to government authorities, etc.
・Appropriate accounting procedures.
・Prohibition of criminal acts
・Ensuring the quality of products and services
Compliance with rules
・Compliance with internal regulationsInformation management and information security
・Protection of personal dataUse of social media
・Prevention of insider trading
・Protection of intellectual property rights
・Prohibition of mixing public and private life
・Compliance with road traffic laws and etiquette
Social relations
・Prohibition of unfair trade
・Prohibition of unfair transactions
・Environmental protection measures
・Prohibition of bribery and excessive business entertainment
Initiatives to strengthen compliance
The Company is working to strengthen compliance throughout the Group, and the Board of Directors reviews compliance with the Code of Business Conduct every three years, based on a questionnaire to employees. In addition, we regularly assess and verify the degree of compliance penetration, and update our compliance handbook and other documents, not only with clearly stated rules, but also always from the perspective of our customers and other stayholders.
Whistleblower system
As a system for the early detection and correction of legal and ethical problems at the Company and Group companies, we have established a Business Ethics Hotline System to receive internal reports and consultations from directors, employees and business partners. This system is designed to accept whistleblower reports and questions and consultations regarding legal and ethical issues in business activities (including all corrupt practices and human rights violations listed in the Compliance Handbook), with 44 cases reported to the Group in FY2023 (30 cases in FY2022).
The system is valued 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 terms of implementation, the Business Ethics Hotline System Regulations clearly stipulate that “the confidentiality of whistleblowers must be strictly observed” and that “whistleblowers and those who cooperate with investigations must not be treated unfairly or disadvantaged, and acts of search, retaliation, and discrimination are prohibited.” This is in light of the revised Whistleblower Protection Act, which came into force in June 2022. Furthermore, the status of its operation is regularly reported to the Risk Management Committee and the Board of Directors. Anonymous consultation and reporting are also possible, and a consultation desk has been set up at an external law firm in addition to the Company’s own consultation desk. In addition, to spread awareness of the Business Ethics Hotline System and contact point, posters are displayed in workplaces, and Compliance Cards with contact information for the hotline are utilized.The level of awareness of the corporate ethics hotline system is confirmed through an annual survey.
Reporting and consultation results
| FY2022 | FY2023 | |
|---|---|---|
| Number of business ethics hotlines | 30cases | 44cases |
FY2023 Business Ethics Hotline reporting type (based on reporting)
Business ethics hotline system (in the event of non-compliance) response procedures.
content confirmation
Confirmation of the details of the report from the informant in person, by telephone, fax, email or sealed letter
survey implementation
Conduct necessary investigations in the departments or group companies concerned based on the content of the report.
corrective measures
After confirming the results of the investigation with the Risk Management Office, if facts requiring correction are found, the Risk Management Office encourages workplaces, etc. to take corrective measures and checks the situation after corrective measures have been implemented.
Answer
Response to the informant on the results of the investigation and corrective measures.
If, as a result of the secretariat's investigation, there is a possibility of a serious breach of the law or the impact of a case is deemed to be significant, the matter shall be discussed by the Risk Management Committee.
Corporate ethics hotline
| company-internal contact | Nankai Electric Railway Co., Ltd. | hotline.houmu@nankai.co.jp |  |
| external contact | Lawyers' offices | hotline.nankai@dojima.gr.jp |  |
| ○Available to. | |||
Establishment of a basic policy on anti-corruption
The Group has declared its commitment to preventing corrupt practices, and established the basic policy in April 2022 to realize this commitment. In addition to applying this policy, which prohibits corrupt practices such as the use of force, to all officers and employees, we also require our business partners and others to take anti-corruption measures such as those against bribery of domestic or foreign public officials; bribery, embezzlement, breach of trust, or other unfair business practices in private transactions; laundering or concealment of criminal proceeds; obstruction of justice; other acts in violation of civil, administrative, or criminal laws and regulations concerning the prevention of corrupt practices; and receipt or offering of entertainment or gifts that exceed the scope of socially accepted norms or common sense.
In accordance with the provisions of this policy, we are working to disseminate and train employees on this policy through the Compliance Handbook and other means, formulate and disseminate an implementation program, establish a consultation service, and ensure that information is managed and stored properly.
In addition, compliance training for officers and employees explains anti-corruption considerations and raises anti-corruption awareness.
Prohibition of bribes and excessive hospitality
In the Compliance Handbook, which is available to all officers and employees of the Group, we have published and made it known that bribes and excessive entertainment of public officials, both domestic and foreign, are prohibited.
Bribery of public officials, whether domestic or foreign, is an unacceptable practice.Providing entertainment or gifts to public officials may constitute bribery.
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.
