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.
At the Group, we have an appointed compliance officer who oversees the compliance activities and initiatives of the entire group. In addition, the sales operations department, domestic group companies and overseas regional headquarters, all have an appointed compliance supervisor in place as we work to develop and strengthen the compliance system. The Compliance Officer reports to both the Representative Director, Executive Chairman and CEO and the Representative Director, President and COO 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.
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)
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.
| Number of attendees of compliance education* (FY2022) |
269 |
|---|---|
*Excluding e-learning attendees, only training conducted by our company Legal Department
| Attendance rate for the Code of Conduct e-learning* (October 2022 - March 2023 results) |
97% (51,364 attendees in total) |
|---|---|
*Number of training items: 8 (safety and health, company assets, internal reporting, bribery, intellectual property, conflict of interest, export, money laundering)
Number of target companies: 83 (the Company, domestic/overseas group companies)
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* |
| Familiarization through in-house newsletters | |
| Dissemination of message from the Top in the four overseas regions, each area headquarters | |
| Dissemination of message from the Top in the group companies in domestic | |
| Case study of compliance in general | |
| Acquisition of written pledge relating to the observance of codes of conduct | All managers in Japan and abroad |
*20 domestic group companies including the Company, 62 overseas group companies
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 Hospitalities and Gifts" as well as 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.
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. As a result of screening 230 outsourced companies in Japan and overseas that have frequent contact with public officials after revising the regulations, 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.
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|
| FY2022 | |
|---|---|
| Scope of screening* | 236 companies |
| Execution rate | 97% |
*Contractors for customs clearance of the Company, domestic/overseas group companies
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. 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.
To further improve internal awareness of "Group In-company Compliance Reporting System", posters for dissemination were prepared in 20 languages and posted in each office.
| Method of reporting | |
|---|---|
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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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 FY 2022, we invited an outside attorney to conduct internal training for investigators of whistleblowing cases in domestic group companies to spread understanding of operation of a whistleblowing system that complies with the revised Whistleblower Protection Act.
*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)
| FY2018 | FY2019 | FY2020 | FY2021 | FY2022 | |
|---|---|---|---|---|---|
| Domestic | 36 | 35 | 50 | 64 | 34 |
| Overseas | 6 | 9 | 4 | 3 | 16 |
| Total | 42 | 44 | 54 | 67 | 50 |
The numbers of violations of anti-corruption and competition laws and regulations in FY2022 are as follows.
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 FY2022 (thousands of yen) |
1,970 |
|---|
The following is compliance data including number of compliance training conducted, number of whistleblowing reports and consultation, etc.
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