Governance

Compliance

Initiatives to Ensure Compliance

As the basis of its compliance structure, the Group has formulated the Compliance Management Regulations of the Group to stipulate the codes of conduct that directors (excluding directors who are audit and supervisory committee members) and employees should comply with, and is deeply aware of its corporate social responsibility. At the same time, the Group has compiled a compliance manual to further clarify matters that must be observed by its officers and employees, and ensures that they follow this manual.

Group Compliance Hotline

The Group has established a Group Compliance Hotline System (internal reporting system) pursuant to the Compliance Management Regulations of the Group to prevent violations of laws and regulations, as well as the Articles of Incorporation.

Protection of informants

The system allows reports to be made anonymously and ensures that persons who make such reports will not be treated disadvantageously.

Reporting and consultation desk

Internal: Group Compliance Hotline (Accounting and Administrative Department)
External: Audit and Supervisory Committee of the Company
Number of internal reports in fiscal 2020: 0

Corporate Policy on Bribery

To ensure fair business dealings, the Group’s officers and employees will ensure that their relationships with suppliers, regulatory bodies and other organizations and individuals with whom they come into contact in their duties are fair and transparent. Officers and employees should refrain from giving or receiving gifts or entertainment that exceeds the bounds of common practice, even if no direct business relationship exists.

Basic Views on Excluding Anti-social Forces and Initiatives to Avoid Anti-social Forces

The Group avoids all anti-social forces and groups that pose a threat to civil society’s order and safety, firmly refuses any demands from such groups and does not conduct any transactions with corporations, groups or individuals related to such groups. The Company as a whole maintains a steadfast attitude against anti-social forces in alliance with competent police forces, corporate lawyers and other external professional organizations.

Status of internal rules

The Company stipulates in its “Basic Policy against Anti-social Forces” that its directors (including directors who are audit and supervisory committee members) and employees shall not respond to any inappropriate demands from anti-social forces, and shall take legislative responses in a steadfast manner.

Status of the internal system

1) Current management departments to deal with anti-social forces and persons responsible for the prevention of inappropriate demands

The Company assigns multiple persons responsible for the prevention of inappropriate demands in the Accounting and Administrative Department, and establishes a system to collect and comprehensively manage information regarding anti-social forces.

2) Alliance with external professional organizations

The Company, even in normal times, promotes alliances with external professional organizations, such as the Tokyo Center for Removal of Criminal Organizations and the Special Violence Prevention Measures Association (Tokubouren) under the control of the Tokyo Metropolitan Police Department, in addition to competent police forces and corporate lawyers.

3) Collection and management of information relating to anti-social forces

The Company regularly collects information concerning anti-social forces provided by external professional organizations at the Accounting and Administrative Department, which manages the information and circulates it across the Company, ensuring every member is informed.