Internal Reporting System

Establishing Internal Reporting Contacts

We have established internal reporting system regulations under the internal reporting system and are operating the regulations for promptly assessing and dealing with information on legal violations or potential violations of laws and regulations.
We have also established internal reporting contacts available to all our officers and employees (including contract, temporary, and part-time employees, and those working under contract or other agreements) and former employees. There are three contact points: an internal contact handled by the Compliance Committee Secretariat, an external contact outsourced to a law firm, and an external contact which is composed entirely of outside directors who are Audit & Supervisory Committee members. The external contacts are also fully independent from the company.
We inform all our officers and employees of details of the internal reporting system and contact points through training on joining the company, compliance training, internal information sharing tools, etc. Please see ESG Data for the training initiatives taken by the Company. In addition to the Internal Reporting Contacts, a harassment consultation contact has been established and is managed by the Human Resources Division.

Receipt, Investigation, and Handling of Internal Reporting

Whistleblowers can make anonymous reports by email, using a dedicated form, or by postal mail to each internal reporting contact. After receiving the report, the contact will report to the Compliance Committee and the Audit & Supervisory Committee and conduct a fair and impartial investigation. If illegal activities are uncovered, necessary corrective and recurrence prevention measures will be implemented and violators will be punished in accordance with the provisions of the work regulations.

Protection of Whistleblowers

Each internal reporting contact receives anonymous reports in accordance with the internal reporting system regulations. In addition, we designate contact persons and those in charge of investigations, and stipulate confidentiality obligations to ensure the management of information that identifies whistleblowers and the content of reports, thereby protecting the whistleblowers.
In addition, the internal reporting system regulations prohibit any dismissal, disciplinary action, demotion, salary reduction, disadvantageous reassignment, relocation, or transfer, encouragement to retire, or any other disadvantageous treatment of whistleblowers. The regulations stipulate that if disadvantageous treatment is found against whistleblowers, relief and restorative measures will be taken and violators will be punished in accordance with the work regulations.

How the Internal Reporting System Works

Please see ESG Data for the number of whistleblowing reports to the Internal Reporting Contacts.
The Compliance Committee, the Audit & Supervisory Committee, and Board of Directors receive reports on the content of each report and the investigation results, and monitor and supervise how the internal reporting system works.

Addressing Bribery Risks

Establishing Behavioral Guidelines

We believe raising awareness of bribery is vital to our accelerated business development in Japan and overseas. In response, we have established basic anti-bribery principles and specific behavioral guidelines. Moreover, to further reinforce ethical conduct and attitudes, we will use our code of conduct to do our utmost to prevent bribery-related acts (including facilitation payments) by not tolerating any acts that violate national and international anti-bribery laws including Japanese Penal Code and Unfair Competition Prevention Act, U.S. Foreign Corrupt Practice Act, and UK Bribery Act.

Initiatives to Prevent Bribery and Corruption

We have established the basic policy regarding prevention of bribery and corruption and the Bribery and Corruption Prevention Regulations, which we make known to our employees along with the operational guidelines on entertainment, meals, or gifts. In addition, we provide employee training to deepen their understanding of the policy, the regulations, and the guidelines. Please see ESG Data for the training initiatives taken by the Company.
Based on the countries and regions where we operate, our business activities, our business partners, and the results of compliance training questionnaires, the Compliance Committee Secretariat compiles bribery risks and the Compliance Committee evaluates them. In order to prevent the provision of cash or other benefits to a public servant or person with equivalent status (hereinafter referred to as “public servant”) with the intention of influencing his/her service acts regardless of whether in Japan or abroad, the Compliance Committee Secretariat monitors the approval process for entertainment, meals or gifts provided to public servants by our officers and employees. In addition, we keep accurate and appropriate record of approval process and accounting ledgers, etc. regarding all transactions and dispositions of assets to ensure compliance with the basic policy regarding prevention of bribery and corruption and the Bribery and Corruption Prevention Regulations.

Consulting/Reporting Contacts for Officers or Employees

We have set up internal reporting contacts to consult and report bribery and corruption within our group. Please see the Internal Reporting System above for the details and operation status of the internal reporting contacts.
There were no cases of significant compliance violations or legal actions taken by the authorities regarding bribery and corruption during FY2023.

Addressing Antisocial Forces

Our policy against antisocial forces and groups (such as organized crime groups, members or quasi-members of organized crime groups, companies affiliated with organized crime groups, corporate racketeers, a rogue adopting social movements as its slogan, and crime groups specialized in intellectual crimes) that threaten social order and safety is defined in our Basic Policy against Antisocial Forces. We fully recognize the importance of cutting all ties with antisocial forces from the perspective of social responsibility, compliance, and corporate defense, and all our officers and employees will strive to ensure the appropriateness of and safety in our duties by complying with this Basic Policy.

Conducting Internal Audits

The Internal Auditing Department reports directly to the Representative Director. It conducts periodic internal audits of each department and organization to confirm their compliance with internal regulations. Specifically, it prepares an internal audit plan for each fiscal year and provides suggestions and guidance for improving operations as required. It also confirms that suggested improvements are made. Results are then reported to the Representative Director and the audited departments. Additionally, it establishes regular opportunities for collaboration with the Audit & Supervisory Committee and accounting auditors to share information necessary for audits.

Conducting of Various Types of Training

We ensure all officers and employees of the Group undertake training on preventing workplace harassment and correctly understand factors causing harassment, such as abuse of one’s position of power and lack of awareness of power dynamics and inadequate understanding and knowledge about different values, as well as specific ways to prevent harassment. Besides formulating management policies to prevent insider trading, we strive to improve officers’ and employees’ awareness and knowledge of legal compliance through regular training sessions on relevant regulations. Please see ESG Data for the compliance-related training initiatives taken by the Company.
As a goal for the fiscal year ending May 2030, we have set a target of achieving a 100% participation in compliance-related training.