In accordance with the principles set forth in the Corporate Ethics Guidelines, the Group defines compliance as the observance of laws, regulations, rules and various policies as well as maintaining high ethics as it conducts corporate business activities. We believe that by continuing to conduct sound corporate business activities based on compliance with rules and ethics, we can earn the trust of many stakeholders, including shareholders, customers, business partners, and local communities, paving the way for increased corporate value.
Based on this concept, the group has established the Compliance Code of Conduct. We have set up various systems under the leadership of the Compliance Committee, which is chaired by top management.

The Compliance Committee is established under the supervision of the Board of Directors and the Audit & Supervisory Committee. It consists of the Chair, Full-time Audit & Supervisory Committee Members, the Officer in Charge of Compliance, the General Manager of the Human Resources Dept., and the General Manager of the Corporate Planning Dept. The President and CEO, who is the general supervisor of the compliance system, has been appointed as the Chair of the Compliance Committee.
The Compliance Committee will specifically clarify as much as possible any matters that may pose a risk of violating laws, regulations, and corporate ethics during the course of corporate activities. The committee will conduct education and awareness-raising activities for Officers and employees, as well as strive to rigorously ensure compliance with laws, regulations and corporate ethics, and make improvements as needed. In addition to regular meetings held twice a year, the committee will hold extraordinary meetings as necessary. Furthermore, the details of these deliberations are reported to the Board of Directors and the Audit Committee.

At the group, in cases where a problem has occurred, is occurring, or may occur from a compliance perspective, the problem is normally reported through worksite communication channels. However, the Company anticipates that there may be cases in which the particular situation makes reporting via worksite communication channels difficult. For this reason, in addition to the normal reporting route, the Company has established an internal reporting (whistleblowing) system to allow an informant who discovers a problem to directly report it to the contact points.

The group believes that compliance at companies is implemented effectively when their officers and employees have a firm grasp of the significance of compliance, and act in line with it not only in corporate business activities but also in their daily lives in society. Based on this belief, the company and its group companies conduct various compliance training programs, in principle, once a year.
Employees who were not affiliated with the Company at the time various training programs were offered due to the timing of when they joined the Company will receive training as needed when they join the Company. In addition to other measures, training materials are distributed to these employees.

The Group pursues initiatives to implement thorough Group-wide compliance and to ensure that it is put into practice, led by the Compliance Committee and Internal Control Committee.

The Compliance Committee, which holds regular meetings twice a year, monitors the status of compliance on a semi-annual basis to strengthen the monitoring system for the prevention of corruption and bribery. The committee also regularly conducts educational activities on compliance with laws, regulations, and corporate ethics, covering themes such as prevention of insider trading, prevention of harassment, and vocational education and training, with a view to preventing violations. As part of our compliance education efforts, the Company’s corporate lawyer conducted training using harassment training videos, with all employees of the Company and the Group companies taking part. In addition, with the establishment and operation of TechMatrix Group contact points for harassment consultation on April 1, 2023, we are working to build and improve our system for thorough compliance across the Group.

The Internal Control Committee is an advisory body of the President, who also serves as its chair. It convenes twice a month as a rule to discuss and report on matters concerning the Group’s internal control in general. Internal control includes all control activities conducted by the Company and the Group themselves, centered on the internal control system and ISMS. The Internal Audit Office, a member of this committee, is responsible for independently evaluating the status of development and operation of compliance systems in the Company and the Group. This section drives the PDCA cycle by encouraging improvements as necessary and through ongoing monitoring. The Internal Control Office, also a member of the committee, is responsible for ensuring that the internal controls that should be implemented in the organization have taken firm root in the individual divisions. In FY2024, it was made clear that this section would fulfill the function of legal officer, including reviewing company-wide legal affairs from a bird’s eye view. For more efficient and effective reviews of contracts on a day-to-day basis, we have implemented an AI-based contract checking service.