Basic Concept

In line with our philosophy, our basic policy is to conduct appropriate corporate activities based on high ethical standards. We believe it is essential to develop our business fairly and responsibly, using the added value we generate as a source of competitiveness. Based on this approach, we have identified “ensure compliance” as one of our material issues to prioritize. In line with this, we are making efforts to instill an awareness of compliance among all employees.

Major Initiatives

Establishing Compliance Committee

In line with our Compliance Regulations, which stipulate basic matters related to compliance, we have established a Compliance Committee. The Committee is chaired by the Representative Director who also has ultimate responsibility for compliance. It comprises full-time directors and the heads of the Internal Auditing Department, Legal Department, and Human Resources Division. The Compliance Committee helps formulate related policies and measures and provides overall compliance monitoring. In principle, the Committee meets once a year, but it also meets as needed in the event of misconduct or other irregularities.

Establishing Internal Reporting Contacts

We have established internal reporting structure regulations for promptly assessing and dealing with information on violations or potential violations of laws and regulations. We have also established internal reporting contacts available to all employees (including contract, temporary, and part-time employees) and former employees. We have established three contact points alongside the Internal Reporting Contacts handled by the Internal Auditing Department. Others include an external contact outsourced to an outside law firm and an external contact handled by the Audit & Supervisory Committee, which is composed entirely of outside directors who are also Committee members. In accordance with the Whistle-Blower Protection Act, the content and privacy of consultations are protected at the reporting stage, and those making reports are fully protected from prejudicial treatment. In addition to the Internal Reporting Contacts, a Harassment Consultation Contact has been established and is managed by the Human Resources Division under strict confidentiality, so employees can feel comfortable about discussing harassment issues with us.

Addressing Bribery Risks

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).

Addressing Antisocial Forces

Our policy against antisocial forces and groups 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 directors, 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 Committee and accounting auditors to share information necessary for audits.

Conducting of Various Types of Training

Conducting, for all our directors, officers and employees, training sessions covering the prevention of various forms of harassment in the workplace, we are working to foster a correct understanding with regard to matters that contribute to occurrences of harassment, specific methods for its prevention and other aspects. Those matters include “abuse of rank/lack of awareness in the workplace” and a “lack of understanding and knowledge of values.” After having established insider trading control rules, we are also striving to improve the awareness and knowledge of legal compliance among our employees by, for example, conducting seminars and training sessions on insider trading regulations on a regular basis. As a goal for the fiscal year ending May 2030, we have set a target of achieving a 100% participation rate in compliance-related training.