Compliance
In order to ensure management in compliance with laws and regulations, the Group has put in place a system to clarify compliance functions and set a compliance basic policy, including matters concerning anti-corruption, to be observed by all officers and employees, to ensure thorough compliance with laws and regulations, company rules, and corporate ethics. We have also established the Group Code of Conduct defining how all officers and employees should act in their daily operations as it is vital for the entire group not only to comply with laws and regulations, including anti-corruption laws and competition laws, but also to act in accordance with corporate ethics in order to meet trust and expectations of the society. Furthermore, we ensure thorough compliance to foster a corporate culture that values corporate ethics and compliance by actively providing compliance trainings and awareness projects, including e-learning, companywide group seminars and compliance meetings.
LOGISTEED Group Code of Conduct (PDF format, 396Kbytes)
Compliance Promotion System
At the Group, we have an appointed compliance officer who oversees the compliance activities and initiatives of the entire group. In addition, domestic and overseas group companies, all have an appointed compliance supervisor in place as we work to develop and strengthen the compliance system. The Compliance Officer reports to the Representative Director, Executive Chairman, President and CEO regarding the status of compliance, including status of anti-corruption-related matters (bribery or corrupt practices, conflict of interest, insider trading, money laundering, etc.) and competition law, within the Group. The Compliance Officer also regularly reports to the Audit & Supervisory Board, and the Company's compliance measures are implemented under a system that also enables supervision by the Board of Directors.
Compliance promotion structure
Compliance meeting
We hold Compliance Meetings for the purpose of information sharing and opinion exchanges relating to compliance targeting persons in charge of compliance in Group companies, for familiarization with compliance-related measures including matters concerning anti-corruption and thorough prevention of scandals. (domestic: 2 times/year, overseas: once overall, once in area unit)
Initiatives to Enhance Compliance Base
Group compliance reference card
Since 2016, we have been distributing the group compliance reference card to all officers and employees of our group to promote awareness of the Group Code of Conduct.
It contains a summary of the code of conduct, flowcharts to be used as a reference in difficult situations regarding compliance, and other things that will help officers and employees to take appropriate actions.
In 2018, the contents of the card were carefully selected and revised to be simpler, and easier to read and understand. The card is translated into 19 languages and distributed to all of overseas officers and employees.
Main items listed on the reference card
- Occupational safety and health / Compliance with labor standard laws and regulations
- Prohibition of harassment
- Respect for human rights
- Information security
- Bribery or corrupt practice prevention / Prevention of competition law violations such as cartels and bid rigging
- Export and import control
- Environmental protection etc.
Compliance education
To build a solid corporate culture that will not accept any compliance violations, we provide rank-based group trainings for compliance education targeting new employees, young employees, new assistant managers/managers, new directors of domestic group companies, in addition to e-learning for all employees including officers, for the purpose of deepening understanding of anticorruption laws, warehousing business law, etc. The Legal Department also implements training sessions travelling around sites.
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Number of attendees of compliance education* (FY2023) |
194 |
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*Excluding e-learning attendees, only training conducted by our company Legal Department
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Attendance rate for the Code of Conduct e-learning* (April 2023 - March 2024 results) |
98.5% (81,955 attendees in total) |
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*
Number of training items: 8 (severance of antisocial forces, document management, human rights, competition law, bribery, internal reporting, safety and health, intellectual property),
Number of target companies: 82 (the Company, domestic/overseas group companies)
Group Code of Conduct Month
Since 2019, October of each year has been designated the Group Code of Conduct Month, and we have been striving for thorough compliance with laws and regulations in the Group as a whole and establishment of corporate ethics from the example of top leadership.
| Activities | Applies to |
|---|---|
| Dissemination of Top Message | All employees* |
| Self-inspection using "compliance checklist" | |
| Case study of compliance in general | |
| Implementation of code of conduct education on "human rights," "competition law," and "bribery" | |
| Acquisition of written pledge relating to the observance of codes of conduct | All managers in Japan and abroad |
* 18 domestic group companies including the Company, 64 overseas group companies
Initiatives to prevent bribery
We recognize that anti-corruption is one of the most important compliance issues, and we are working to strengthen our management system particularly for bribery in Japan and overseas.
In FY2022, we revised "Anti-Corruption Regulations" and "Global Guideline for Hospitalities and Gifts." and we established and reviewed rules and regulations such as setting "Anti-Corruption Compliance Guidelines." In order to ensure dissemination of the contents, operation, and specific rules of conduct, we also explained at various meetings, trainings, etc. and provided e-learning for all Group employees. In FY2023, we provided education by local law firms to customs clearance staff at overseas Group companies and to business partners to whom customs clearance operations are outsourced.
Implementation of screening of business partners for prevention of bribery by business partners
The Group recognizes that reducing the risk of bribery in the supply chain is essential for creating a responsible supply chain. The Regulations on Bribery Prevention revised in FY2022 stipulated screening of business partners for the prevention of bribery as a process to reduce risks in the supply chain. After revising the regulations, we screened 230 outsourced companies in Japan and overseas that are judged to be high risk by external experts and the Executive Committee Meeting because they have frequent contact with public officials, but no concerns about bribery were found at the present time. In future, in addition to periodically conducting screening, we intend to encourage each business partner to improve initiatives to prevent bribery as needed.
Main screening items
- Relationships with government organizations
- Accounting books and records
- Dissemination of LOGISTEED Group Policy on Bribery Prevention
- Compliance with applicable laws and regulations
- Use of third-party companies
- Declaration and confirmation of data privacy, etc.
Whistleblowing system
The Group has established an whistleblowing system, which allows employees and other concerned parties to report illegal and/or inappropriate actions with a sense of security in order to detect and correct them early on. In addition to the internal points of contact for reporting, we have also established a system for reporting to an external lawyer as an external point of contact.
This system is available to all workers at our group, including directors, full-time staff, part-timers and temporary workers at both the Company itself and all of its group companies as well as employees of suppliers to our company or its Group companies.
When a report is received, the facts are confirmed with the person who made the report, the person who is the subject of the report, and any related third parties, and if we find any violations, we work to correct them and prevent them from happening again. We also check to make sure that the person who made the report has not received unfair treatment such retaliation. In addition, We protect the personal information of the caller, and ensures confidentiality of the report, as well as prohibiting any disadvantageous treatment related to the issue, in order to protect whistleblowers.
Specifically, we require investigators of whistleblower reports to submit a pledge to comply with the company's whistleblower regulations such as maintaining strict confidentiality of reports and prohibiting disadvantageous treatment of whistleblowers, and also check that whistleblowers are not treated disadvantageously after making a report.
Poster for dissemination of whistleblowing system
To further improve internal awareness of "Group In-company Compliance Reporting System", posters for dissemination were prepared in 18 languages and posted in each office.
- Information that can identify a whistleblower will not be disclosed without advance consent.
- The whistleblower will not be treated disadvantageously for whistleblowing.
| Method of reporting |
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The following points of contact are equipped with a system for reporting by sealed letter, e-mail, website entry, etc.
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| Information that can be reported |
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Whistleblowing Compliance Management System (WCMS) certification
In June 2021, we become a registered company of "Whistleblowing Compliance Management System certification (self-declaration of conformity registration system)" under the jurisdiction of Consumer Affairs Agency of Japan. "Whistleblowing Compliance Management System certification (self-declaration of conformity registration system)" is a system introduced by the Consumer Affairs Agency in February 2019 to promote the appropriate maintenance and operation of the whistleblower system, which is an important element of corporate internal controls and corporate governance. Businesses submit an application with an evaluation of their own whistleblowing system, which is reviewed by a registration agency designated by the Consumer Affairs Agency to confirm that it conforms to the certification standards*. Please note that this system certification is suspended for the time being as a new system will be considered following the revision of the Whistleblower Protection Act in June 2022.
In FY2023, in order to further protect anonymity, we have changed our policy so that we do not request disclosure of the name or position of anonymous whistleblowers when reports are received.
*Certification standards for whistleblower systems based on the "Guidelines for Private Enterprises Regarding the Development and Operation of Internal Reporting Systems Based on the Whistleblower Protection Act" (December 9, 2016, Consumer Affairs Agency)
Number of whistle-blowing reports and consultations
| FY2019 | FY2020 | FY2021 | FY2022 | FY2023 | |
|---|---|---|---|---|---|
| Domestic | 35 | 50 | 64 | 34 | 70 |
| Overseas | 9 | 4 | 3 | 16 | 8 |
| Total | 44 | 54 | 67 | 50 | 78 |
Non-compliance with laws and regulations
The numbers of violations of anti-corruption and competition laws and regulations in FY2023 are as follows.
- Costs incurred for fines, etc. for violations of anti-corruption and competition laws and regulations: 0 incidents (0 yen)
- Number of employees fired for violations of anti-corruption and competition laws and regulations: 0
Political contributions
We stipulate in the Group Code of Conduct that political contributions can only be made if the philosophy of the political organization or politician is in line with our corporate philosophy. When making contributions, we comply with the Political Funds Control Act and other related laws and regulations.
| Amount of political contributions in FY2023 (thousands of yen) | 1,970 |
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Compliance Data
The following is compliance data including number of compliance training conducted, number of whistleblowing reports and consultation, etc.