Compliance

We believe it is critical for all members of the Aisan Group to ensure compliance in meeting the expectations of all stakeholders in order to achieve sustainable growth and improve our trustworthiness. Based on this belief, we formulated the Aisan Group Action Agenda that stipulates the Group’s universal values and action guidelines in 2007, and declared nine action items including legal compliance. In addition, we formulated the Compliance Guidelines in 2015, and established them as action guidelines to be followed by each and every employee, and have ensured that all employees are aware of them.

Our Governance Meeting, chaired by the Corporate Planning Executive Officer, confirms and follows up on the status of compliance with corporate ethics guidelines and laws and regulations, as well as the status of compliance activities. The results are reported and deliberated twice a year at the Sustainability Committee, which is chaired by the CRO.
The results of these deliberations and other compliance activities are shared across the company by the Corporate Planning Department, which serves as the secretariat, and are reflected in the activities of each workplace. This mechanism ensures that management and the frontlines work in unison to ensure thorough compliance.
In addition, the Board of Directors supervises the Action guideline, Ethical Guidelines, and compliance activity in general, including anti-corruption* measures. The Board of Directors receives regular reports on the number of compliance violations, and is responsible for oversight of compliance-related initiatives. It also carries out regular reviews of the effectiveness of the Code of Conduct and Ethical Guidelines.

• A comprehensive term encompassing all forms of corruption, including bribery, insider trading, unfair trading, anti-competitive conduct, embezzlement, and money laundering.

The Compliance Guidelines outline compliance items that should be shared and observed throughout the Group. In order for each employee to deepen their knowledge of compliance and take sensible actions, we also attached a commentary on the guidelines for distribution to all Group employees.

We cultivate awareness of legal and regulatory compliance by regularly providing information to employees, including through level-based training, e-learning modules focused on various compliance themes, and the distribution of internal circulars and e-mail newsletters that introduce case examples of compliance violations in day-to-day activities.

In order to further deepen the understanding of the Compliance Guidelines, we provide function-specific training that is tailored to departments where a more specialist knowledge is required, and level-specific training targeting managers and supervisors. Considering the growing importance of compliance as a social issue, we are enhancing related activities that incorporate measures to prevent harassment as well as bribery and other forms of corruption.

We provide the following e-learning to all employees to ensure that employees can access these important matters at any time.

• Labor management and harassment
• Copyright
• Compliance and whistleblowing
• Insider trading prevention
• Subcontract Act
• Information security
• Antitrust Act (Cartel Regulations)
• Unfair Competition Prevention Act
• Bribery prevention

We have written a Harassment Prevention Handbook and provide level-based training for managers and general employees. We are working to promote a correct understanding of harassment through our education and awareness activities, and build a corporate culture that does not tolerate harassment.

We conduct compliance awareness surveys of all employees to quantify the outcomes of past initiatives, and utilize the results in our education and awareness activities to further boost employee awareness.

To enable the early detection and prevention of compliance violations, breaches of internal rules or laws, and corruption in the course of business, we have established and operate a reporting and consultation desk that accepts reports and inquiries from employees and their families. The helpline channels are tailored to the nature of the issue and the person reporting it, and include a harassment hotline, a supplier hotline, and a Global Helpline for our domestic and overseas companies.
In all cases, we have established systems in compliance with whistleblower protection laws to ensure that whistleblowers are appropriately protected.

Our Aisan Group Action Agenda, Compliance Guidelines, and Sustainability Guidelines clearly state that we do not engage in conduct that would violate applicable competition laws, including private monopolization, unreasonable restraint of trade (such as cartels and bid-rigging), unfair trade practices, and abuse of superior bargaining positions. We promote awareness through level-based and workplace-based training.

To prevent insider trading by Aisan Group directors, employees, and other related persons, we have established Insider Trading Prevention Guidelines, which we promote awareness of through internal training programs and enforce strictly.

Our directors and employees work to prevent all kinds of corruption, including bribery, conflict of interest, anticompetitive activity, and insider trading, based on the Aisan Group Action Agenda, Compliance Guidelines, Sustainability Guidelines, and other policies. In fiscal 2024, no employees were subject to disciplinary action or dismissal for violations of anti-corruption policies and guidelines. There were no material fines or non-monetary related to corruption (bribery).

To prevent corrupt activities within the supply chain, we have established Supplier Sustainability Guidelines that set forth initiatives to prevent corruption, including bribes and conflict of interest, which we disseminate with suppliers and other entities at supplier meetings. As part of these measures, we carry out due diligence when engaging new agents and other business partners, to confirm the presence or absence of red flags according to our definition.

To facilitate the prevention and prompt discovery of, and corrective action against conduct that breaches our anti-corruption policies (including bribery and conflict of interest) and our Group Action Agenda, or violates relevant laws and regulations, we have established a Supplier Consultation Desk as a channel for confidential and anonymous reporting.

We have established systems for the appropriate protection of whistleblowers that allow the confidential and anonymous reporting of activities that breach our standards, group Code of Conduct for preventing corruption (including bribery and conflict of interest), and that violate relevant laws.
We accept reports from various stakeholders through our corporate website. If potential violations are identified, we respond in accordance with the prescribed standards and procedures.

We work to nurture an awareness of compliance matters by identifying business activities and workplaces with a particularly high risk of infringing the Code of Conduct, Ethical Guidelines, and measures to prevent corruption including bribery, as well as by providing regular education, enhancing department-specific training, and introducing case studies.

In the event of possible breaches of the Group Code of Conduct, Ethical Guidelines, and violations of laws, work rules, and other internal rules, we consider establishing independent committees or investigating the activity internally, based on discussion with external experts where required. Employees found to have committed violations are subject to disciplinary action, and deliberations and disciplinary measures are carried out in accordance with prescribed standards and procedures, including the rules of the Rewards and Disciplinary Committee.