We have established the IRJ Group Compliance Hotline as a whistle-blowing system for reporting an actual or a potential ethical (moral), legal, or regulatory violation, both at the organizational level and at the individual level.
This system is intended to prevent violations and unethical conduct. Furthermore, in the event of an actual legal or regulatory violation or unethical conduct, it enables the Group to act quickly and appropriately, with the expectation that this will have a self-purifying effect on the Group.
The IRJ Group Compliance Hotline is available not only to Group employees but to all workers, including temporary employees, part-time employees and other fixed-term employees, and contract employees, and to all related parties, including those who have transactions with the Group.
Compliance Hotline System
If Group employees, irrespective of their department, observe an actual or potential ethical (moral), legal, or regulatory violation (hereafter referred to as “compliance violation”) within the Company, normally they are required to use the standard chain of command to report the issue to a superior so that it can be dealt with. However, if they believe that the issue would not be addressed speedily and effectively through normal reporting channels, they can report the issue via the IRJ Group Compliance Hotline.
Internal contact point:
Group Compliance Hotline, Compliance Committee Internal Reporting Representative
- Address for written reports:
IR Japan Holdings, Ltd., Group Compliance Hotline, Compliance Committee Internal Reporting Representative
26th floor, Kasumigaseki Building, 2-5, Kasumigaseki 3-chome, Chiyoda-ku, Tokyo 100-6026, JAPAN
- Tel: +81-3-3519-6750 (Main desk) Fax: +81-3-3519-6730
- Dedicated email address: email@example.com
External contact point:
■ Designated Audit and Supervisory Committee Members
- IRJ HD:
Nobuyoshi Yamori, Director, Audit and Supervisory Committee Member
Email address: firstname.lastname@example.org
- IRJ and JOIB:
Kazufumi Onishi, Director, Audit and Supervisory Committee Member
Email address: email@example.com
■ Designated (external) law firm
- AI-EI Law Firm (Managing Partner: Michihiro Mori)
- Contact person: IR Japan Group internal reporting hotline attorney Takahiro Ito
- Tel: +81-3-6205-8444 (Main desk) Fax: +81-3-3519-5595/5596
- Email address: firstname.lastname@example.org
Overview of the Internal Reporting Process
- To ensure that the content of internal reporting is correctly understood, please report in writing when possible.
- For internal reporting in writing, a form is available (as indicated separately) that contains the required items of information. The form can be downloaded on the Internet. Please fill out the form, entering information for each item.
- As a general rule, you should indicate your name when doing internal reporting, to ensure that facts are confirmed promptly and sufficiently, and to make it possible to share the results of the investigation and measures that have been or will be taken. Please be aware that it may not be possible to conduct sufficiently rigorous fact-finding investigations or to provide feedback when internal reporting is done anonymously.
Examples of Content of Internal Reporting
- Violations of the Antimonopoly Act, Unfair Competition Prevention Act, Companies Act, or Penal Code
- Transactions including corruption such as contact with, entertainment of, donations, contributions, or gift-giving to anti-social forces
- Improper accounting
- Issues related to environmental conservation, safety, or disaster prevention
- Labor Standards Act violations, work regulation violations, or other personnel- or labor-related matters
- Sexual harassment or power harassment
- Leakage or involvement in the leakage of confidential information (including insider information) or personal information
Steps Taken When Internal Reporting Is Received
- An investigation will be conducted on any matter reported to the internal reporting hotline unless there is due cause not to do so.
- If deemed necessary for the execution of a sufficiently rigorous investigation of a reported matter, the investigation will be carried out by a party other than the Compliance Committee, such as the director in charge of the division involved in the matter, a legal/regulatory compliance officer, or the division with authority over the matter in question.
- If the investigation determines that there has been an infraction of laws, regulations, etc., directives such as corrective measure instructions will be given to the Representative Director and President of the Company or to that of the Group company, to the director responsible for the Group company involved in the legal or regulatory infraction, or to the legal/regulatory compliance officer of the said Group company.
- If the investigation determines that there has been an infraction, appropriate sanctions will be levied against all officers and employees who engaged in the said infraction.
- The Compliance Committee representative will provide feedback on the results of the investigation to the whistle-blower, unless the whistle-blower’s contact information is unknown.
- The utmost care will be taken to protect the privacy of the whistle-blower and the fact that internal reporting has been received, and the content of the said reporting will be kept confidential from everyone except those involved in the investigation of the internal reporting.
- If the whistle-blower is a Company employee, temporary employee, part-time employee or other fixed-term employee, or contract employee, the whistle-blower will not be subject to adverse treatment, such as employment termination, reassignment, discriminatory treatment, or contract termination, as a result of internal reporting.
- If the whistle-blower is an officer or an employee of a client or supplier, the client or supplier will not be subject to adverse business treatment as a result of internal reporting.
- However, the above will not apply if the whistle-blower intentionally provides false information or the like to frame another party or if the internal reporting is done to threaten, blackmail, or engage in other illegal behavior.
- Sanctions levied against an officer or an employee of the Group involved in a legal or regulatory infraction may be reduced if the said officer or employee voluntarily reports the matter to the internal reporting hotline and/or cooperates in the investigation of the matter.