In order to enhance compliance, our group established the Compliance Committee chaired by the Representative Director（Regular meetings twice a year and special meetings as required）. This committee conducts activities to prevent noncompliance issues under the supervision of the CSR and Sustainability Committee, an advisory committee to the Board of Directors, chaired by an external director. It will also give instructions about the measures to be taken in the event of a noncompliance incident and monitor the implementation of the measures.
In FY2023, the Compliance Committee met twice to report and discuss responses to amendments to laws and regulations, compliance activities, improving the effectiveness of the whistle-blowing system at overseas Group companies, and compliance awareness survey results and follow-up activities.
Compliance Promotion SystemWe have established the Corporate Ethics Helpline as an internal reporting system available to employees and suppliers seeking consultation and making reports regarding compliance.
In addition to setting up the Compliance Committee Secretariat as an internal point of contact, we have also set up external private contractors.
We are striving to improve convenience by, for example, allowing consultations and reporting outside working hours and on holidays. Anonymous consultations and reports are also accepted, and whistleblowers are thoroughly protected so that whistleblowers are not identified and are not disadvantaged as a result of reporting.
The hotline accepts consultations and reports when any violation of compliance, including harassment, or an act that may result in such violation is known. We investigate the facts of consultations and reports we receive, and if any problems are identified, we promptly deal with them.
In FY2022, there were 97 consultations and reports, including those from employees of Group companies and those related to labor affairs and internal regulations, and we promptly resolved and took corrective actions for the identified problems.
We are continuously working to make the helpline service widely known by measures such as introducing it in training, internal intranet, putting up related posters and distributing carrying cards describing the service.
Also, we have established channels for consultation and making reports at each of our overseas group companies.
With the revised Amendment of the Whistleblower Protection Act enacted in June 2022, we reviewed related regulations and re-informed employees about the corporate ethics helpline.
Flow after report is received via the HelplineTo raise employees’ awareness and knowledge regarding compliance, we are sharing and disseminating information to employees through compliance promoters in each department, and we are continuing to educate them by using the Compliance Guidebook, which summarizes the rules concerning companies and society, the Compliance Newsletter, which provides specific examples of compliance issues that could arise in our daily operations, and the Compliance Promotion Rules (for Managers/Mid-Level Employees), which explains expected roles and behavior, in addition to holding level-specific and theme-specific training.
Moreover, we conduct a compliance awareness survey targeting employees, in order to check employees’ level of understanding about the corporate rules and systems and to examine the corporate culture and identify compliance risks. In FY2023, the survey was conducted with approximately 8,000 domestic group members. we fed back the survey results to each department and identified those departments with issues to be addressed and interviewed.
The Compliance Guidebook provides explanations of the laws and rules that our company and society must comply with, as well as specific prohibited items.
＜Example of Publication Content＞
The Compliance Promotion Book is available in two versions: Managers version and Mid-career Employee version. They serve as guidelines for managers and mid-level leaders to promote compliance in their workplaces. The book contains the necessary behavior, knowledge, and examples for each position.
＜Example of Publication Content＞
We are striving to prevent corruption in line with the statement made in our Corporate Code of Conduct: “We shall promote fair, transparent, free competition and sound trade. We shall also ensure that our relationships and contacts with government agencies and political bodies are of a sound and proper nature.”
We issued the Compliance Guidebook in 2012, in which we set the rules concerning the prevention of corruption, including the prohibition of involvement in political contributions or bribery, and made employees aware of these rules.
Subsequently, in 2013, we issued the Conduct Guidelines Concerning the Giving and Receiving of Gifts and Entertainment to raise employees’ awareness of the issues and prevent them from becoming involved in misconduct. Further, we signed the UN Global Compact in 2016 and formulated an Anti-Corruption Policy for our employees in 2018, openly reaffirming our commitment to preventing corruption.
We are thus working to prevent corruption in line with the guidelines and others. We respond to any violations of the anti-corruption rules mainly through the Compliance Committee. Our overseas Group companies are also taking action to prevent corruption, especially to prohibit and prevent bribery of civil servants and facilitation payment, including providing employees with related education and conducting surveys on local laws. We also request that suppliers refrain from acts of bribery through our CSR Procurement Guidelines. In FY2022, there were no violations of related laws and regulations across the Group.
We will take a firm stance against anti-social activities and forces/organizations. We will not engage in any act that facilitates such activities, including purchasing something, providing benefits and participating in money laundering, including from suppliers associated with them.
We have established internal regulations to prevent insider trading, which obstructs fair trading in the stock market.
Our internal regulations set standards of conduct regarding the management of our internal information and the buying and selling of stocks, etc. of our company or other companies. Compliance with these rules will prevent insider trading by our officers, employees, and ourselves.
Taking seriously our violation of the Anti-Monopoly Act of Japan, as uncovered in FY2014, we have established a system to promote compliance with competition laws and to ensure legal compliance both within and outside the country.
In Japan, we formulated the Anti-Monopoly Act Compliance Manual and distributed copies to employees while holding a range of related seminars internally for both executives and employees. Moreover, we have introduced an in-house e-mail inspection system to monitor and prevent recurring violations of the competition law.
Our overseas Group companies are required to report the activity status regarding compliance with competition laws to Niterra on a regular basis. In addition, the company’s teams in charge of affairs concerning competition laws and compliance, where they audit the companies’ compliance systems and implementation status and check whether local employees are sufficiently aware of the related rules. Seminars featuring guest speakers are also held.
We will continue our education and auditing activities to ensure compliance with competition laws both in Japan and abroad.
We comply with domestic laws and regulations based on the Foreign Exchange and Foreign Trade Act in accordance with the multilateral export control regime (MECR) established for international peace and safety. In addition, we have established related internal rules and an in-house export control organization.
We also conduct awareness-raising and inspection activities targeting departments engaged in export control, thereby ensuring and enhancing our export control in compliance with the related laws and regulations. We are working to prevent the destabilization of international affairs by focusing on preventing the outflow of sensitive technology as well as cargo that can be diverted to military use.
In addition, we have established a system to understand and respond to the international situation related to export control and revision trends of related laws and regulations.
In accordance with revisions to export control-related laws and regulations that came into force in May 2022, we have reviewed related regulations and made them known to relevant departments.