Promoting Compliance

Compliance Promotion System

Everyone in the Group understands that maintaining relationships of trust with stakeholders is the foundation of our sustainable growth together with the communities that we serve. To reinforce this concept, we created a Group Corporate Philosophy, along with a Corporate Code of Conduct, designed for putting the spirit of our philosophy into practice. Moreover, an Internal Control and Compliance Committee chaired by the president executive officer strives to raise awareness of compliance so that all officers and employees obey all laws and regulations, as well as internal rules, social norms, and business ethics while performing their everyday work.

Whistleblowing System

NS United Kaiun established the Whistleblowing System, both inside and outside of the Company, to accept direct reports from employees who become aware of or have suspicions of contraventions of the law, misconduct, or similar acts committed by executives or other employees in our Group. Both hotlines accept anonymous reporting. Whistleblowers are guaranteed protection from unreasonable treatment as a result of making a report, with the goal of protecting individuals who report company information that is in the public interest. Further, the Company has appointed a third-party lawyer. Additionally, a third-party organization has been newly appointed in April 2022 to serve as a hotline that offers a high level of anonymity.

Internal Controls

Guided by Japan’s Companies Act and Regulation for Enforcement of the Companies Act, the Board of Directors has established a basic internal controls policy, while also working to ensure the reliability of financial reports in accordance with the provisions of the Financial Instruments and Exchange Act.

Internal controls and compliance initiatives taken by corporations have been attracting an increasing amount of public attention. To effectively address these issues across the Company, we organize the Internal Control and Compliance Committee, appointing the president as the chairperson and each executive officer in charge of a business division as a committee member. Furthermore, every department established a system for autonomous internal controls, where they proactively identify local risks in daily operations and makes improvements to mitigate these risks.

We recognize that internal control activities help enhance the quality of our business management, and that financial reports which have high reliability give rise to trust in our Company by our stakeholders and from society. All the executives and employees of the Company will continue to work together to strengthen compliance, establish and implement an appropriate internal control system.

Anti-Corruption

Basic Anti-Corruption Policy

The NS United Kaiun Group has established this policy to ensure compliance with anti-corruption laws and regulations applicable to the countries and regions in which we conduct business activities and to practice behavior that our compatible with social ethics.

This policy was approved by the Board of Directors on January 31, 2023. Subsequent revisions or abolition of this policy will also be determined by approval of the Board of Directors.

All-Hands Discussion on Anti-Corruption Policies

In October every year, we run the ESG Week campaign to enhance employees’ understanding of ESG issues. In fiscal 2023, cross-divisional meetings took place over four days to discuss the following topics

Overall theme

Understanding the Company’s anti-corruption policies

Individual theme

• (1) Avoidance of inappropriate relationships with business partners, including public officials
• (2) Prevention of insider trading
• (3) Prohibition of cartelization
• (4) Practice of appropriate transactions

Third-party Certification

We obtained a third-party certification for systems developed for compliance with international trade law for the first time in March 2017, and have renewed the certification every year since then.

Certification ID：TC 3172-6257

For details, please click here.

Corruption-related Penalty Charges, Surcharges, or Settlement Money

Employees disciplined and dismissed for non-compliance with the Basic Anti-Corruption Policy

Political Contributions

To date, we have not made any political contributions. However, in the event that we do make a political contribution, we will do so in light of our business performance, in compliance with the Political Funds Control Act, and in accordance with appropriate internal procedures.

Compliance with Antitrust Laws

We take measures to ensure executives and employees follow appropriate action and management guidelines to comply with the antitrust law, and implement a system to create and store records of details of contacts with other companies in the same industry depending on the nature of contact.

Penalty Charges, Surcharges, and Settlement Money related to the Antitrust Law and Competition Law

Education and Training

Compliance Awareness Month

Starting in 2010, the year of the corporate merger, the Company has designated October as the month for raising compliance awareness and is engaged in several activities across the Group. The campaign aims to remind all executives and employees of the importance of this theme, implementing a range of activities to enhance their awareness as well as give them the knowledge and information needed to practice compliance.

Ongoing activities

^*The first survey was performed in 2011, the second in 2014, and the third and onward every two years up to 2018.

Employee awareness survey

Our Group strives to build a workplace culture that enables each individual employee to work with peace of mind. As part of the related efforts, we perform employee surveys on internal control and compliance.

The opinions of employees collected through the surveys are used to develop an environment where employees can work at ease, exercising their full potential, and to consider and promote measures to build a culture encouraging them to respond to any issue appropriately by seeking consultation or reporting.

Activities in the past three years

Relevant policies and regulations are posted on internal message boards accessible to all executives and employees throughout the year regardless of Compliance Awareness Month, in order to update their knowledge as necessary.