Initiatives for Compliance
The Company has established a management system aimed at group-wide comprehensive management which enables the Group to perform business operations under the appropriate compliance framework. We will aim to enhance the compliance framework by positioning compliance as one of the most material management tasks.
Organization and structure
We have established the Basic Rules on Group Compliance as the Group’s highest standards for compliance, and thereunder, other relevant rules and regulations systematically. And the contents are revised in a timely manner.
The Compliance Committee established within the Company is responsible for decisions on compliance-related important business execution of the Company and the Group, and for deliberation on matters for analysis, assessment and improvement relevant to group-wide compliance.
In addition to establishing “the Legal and Compliance Group” in the Corporate Management Department as the managing and supervising section in charge of group-wide compliance and assigning the officer responsible for the Corporate Management Department, we are also implementing compliance by assigning a person in charge of legal compliance to each management organizational unit of the Group. Important matters regarding compliance at directly-owned subsidiaries are consulted on and reported to the Corporate Management Department, which is responsible for the guidance, management and supervision thereof, pursuant to the Rules for Management of Companies within the Group.
Compliance program
The Group has established a compliance program as the action plan to realize compliance. Each of the companies within the Group establishes a program based on the Basic Policy on Group Compliance Program developed annually by the Company.
The status of the compliance program performed by companies within the Group is reported to and validated by the Compliance Committee quarterly, and is also subject to the annual overall assessment which is reflected in the next year’s program.
Handling of Violation of Laws
The Basic Rules on Group Compliance provides the handling of violation of laws including irregularities and the system for taking appropriate measures is developed, specified in the rules of irregularities.
Initiative for Compliance Enforcement
The Group has established the system for training and educating employees of each hierarchy of the Group on compliance such as training of the prevention of harassment, corruption, and irregularities for new branch managers and strives to foster and enhance a sense of compliance among them as a top priority issue.
Anti-bribery
The Group shall prohibit bribery such as a reception, the exchange of presents to public officers within the standards concerning compliance with laws and regulations, and ensure employees of the Group to understand them fully.
Internal Reporting Program
The company has established the internal reporting program in response to all employees of the Group to enhance the effectiveness of compliance.
It aims at direct response to employees of the Group and prompt understanding of the problem, and taking measures to prevent violation of laws and rules including harassment, corruption. In addition to the internal section as an internal contact, the Audit Committee and external lawyers accept direct report as an external contact. And also, they accept anonymous reports.
Furthermore, we encourage utilization of the program by putting posters in each departments and video views for all of employees.