Compliance Systems

Having established a Compliance Program, we are working to thoroughly educate all officers and employees about this in order to clarify its basic approach toward corporate ethics and observance of laws and regulations.

We established a Compliance Committee, which is directly under the president, to build and maintain the compliance system while three expert committees, subordinate organizations of the Compliance Committee, address technical issues. To further reinforce the compliance system, we have built a system to request legal opinions when necessary, by inviting attorneys to serve as outside members of the Compliance Committee and expert committees.

The Internal Auditing Department, which is independent of operating divisions and directly under the president, was established as the internal audit department and audits operations and prepares audit reports based on Business Audit Rules.

The Group has no connections to anti-social forces and entities that threaten the order and safety of civil society and refuses all unreasonable demands.

We have established and implement a Compliance Program by systematically creating Conduct Guidelines and Rules of Conduct that are based on the Group Mission Statement and reflect the Company’s ethos that has developed since its establishment.
Group officers and employees thoroughly comply with laws and ordinances and act according to corporate ethics in line with this Compliance Program. It is understood that in order to continue to develop business and enhance corporate value, the most important factor is that each person be honest and possess the confidence and responsibility of a professional, accept the individuality of others and diversity, and make all efforts to achieve targets, and put this into practice.

For violations of laws, regulations, or other compliance-related matters, the Group has established a framework for handling reports through a whistleblowing system operated in accordance with its whistleblower regulations, which include provisions protecting the anonymity of whistleblowers who so desire and safeguarding them against disadvantageous treatment. Under this system, reports may be made either to the Compliance Committee’s consultation desk or to an outside attorney serving as a reporting contact. The whistleblowing system also covers corruption and competition law violations, and the Group has established mechanisms to appropriately investigate and address suspected incidents based on reports from its officers and employees, including temporary staff and contract employees.

*FY2024: Number of reports submitted to the whistleblowing system: 0

The Group strives to ensure fair, transparent, and free competition across all its business activities by complying with both the letter and spirit of competition laws and all other applicable laws and regulations as well as a system of internal rules. The Group prohibits misconduct related to business transactions, including bribery of public officials and similar persons, whether directly or through intermediaries, and responds vigorously to violations in accordance with internal regulations. In addition, the Group has established a Fair Trade Management Committee to monitor compliance with applicable laws such as the Antimonopoly Act and the Unfair Competition Prevention Act in order to promote fair transactions and prevent corruption. As part of this monitoring, the Committee receives written reports twice a year from each business division, purchasing departments, and domestic subsidiaries regarding their compliance status. The results of this monitoring are reported once a year to the Board of Directors through the Compliance Committee as part of the Group’s efforts to strengthen its overall legal compliance framework.

The Group conducts risk assessments of key suppliers focusing on corruption-related matters, including bribery, receipt of improper benefits, and other forms of corrupt conduct. When initiating new business relationships or renewing contracts, the Group carefully reviews each supplier’s business activities, business partners, and past performance in order to assess whether any corruption risk is present. In addition, the Group provides such suppliers with its CSR Procurement Guidelines, which clearly prohibit bribery and require sound business practices, and requests their understanding and compliance.

The Group continuously provides compliance training to all employees through in-house seminars and e-learning programs on topics such as laws and regulations, internal rules, information security, and harassment. Through these initiatives, the Group seeks to further strengthen each employee’s awareness of compliance.

The Group began offering training led by outside counsel on the revised Subcontract Act (now known as the Act on the Promotion of Subcontracting Small and Medium-sized Enterprises), which took effect in January 2026 to expand the scope of covered transactions and business operators. Approximately 100 employees participated in this training.