Tokyu Group’s Compliance
Compliance management is not only intended to prevent corporate scandals, but is also indispensable for us to remain as a brand that is preferred by customers, through enhancement of our corporate value. The Tokyu Group has been proactively promoting compliance-related activities since it made compliance one of the basic stances of the Group’s management in April 2000.
In January 2002, we established the Group’s compliance guidelines as the basic principles of action related to compliance for all officers and employees of the Tokyu Group. Based on these guidelines, each Group company conducts its own activities, in accordance with its business structure and corporate culture, in an effort to promote compliance.
Basic Approach to Compliance
We consider compliance with corporate ethics and laws to be non-negotiable and the most fundamental part of CSR but realize that we need to create systems and offer thorough staff training in order to completely eliminate violations caused by lack of knowledge or awareness. In order to make our understanding of “always doing what should be done” a part of Tokyu Construction’s company culture, we have created action guidelines and norms which we seek to imprint on our staff through the use of training materials, including online learning.
Guidelines for Action / Compliance Code
1. Emphasis on Risk Management
We recognize that risk management is essential to improving our corporate value. We will endeavor to establish a process to manage risks properly.
2. Securing Safety
We recognize that safety is the first priority in every situation in which we provide products and services. We will endeavor to secure safety.
3. Business Operation by Understanding the Needs of Customers
We will properly understand the needs of our customers and provide high-quality technology in conjunction with our business efforts (such as planning, design, and construction). We will have our customers fully understand and be satisfied with the contents and characteristics of our business efforts, and we will conduct business operations in good faith by respecting our customers’ intent.
4. Provision of High-Quality Designs and Construction Products
We will comply with the Building Standards Act and other statutes, and our internal standards regarding product quality, and we will thereby provide high-quality designs and construction products reliable for and satisfactory to our customers.
5. Proper Response to Various Comments from Customers and Neighborhood
We will faithfully and promptly respond to various “comments” from our customers, the neighborhood, and the like. We will make use of such “comments” to improve our business operations and services, and to achieve other similar purposes.
6. Fair and Transparent Decision-Making
We will make decisions in compliance with the statutes and our company rules, and based on appropriate and accountable grounds.
7. Protection of Corporate Property
We will carefully handle our corporate property, which generates our corporate value.
8. Timely, Appropriate, and Fair Information Disclosure and Public Relations Activities
We will endeavor to disclose information to all of our stakeholders (interested parties) and conduct public relations activities timely, appropriately, and equitably to obtain a correct evaluation and understanding.
9. Prohibition of Insider Trading
We will not commit any insider trading or conduct any suspicious transactions of shares or the like.
10. Securing Compliance and Fair Trade
We will understand the laws and regulations, and we will not conduct any illegal transaction or unfair trading.
11. Refusal of Relationship with Antisocial Forces
We will sever transactional or any other relationship with antisocial forces. If any trouble or the like occurs, we will take a tough stance toward such trouble or the like company-wide.
12. Optimal Procurement Activities
We will provide equitable business opportunities to, make fair selections of, and provide optimal procurement to suppliers and other business partners.
13. Appropriate Management of Rules
We will develop and keep officers and employees of our company fully informed of effective company rules according to business performance efficiency and business risks.
14. Appropriate Business Operation and Internal Governance
We will endeavor to conduct business through appropriate procedures, as well as to implement internal control according to our business activities.
15. Respect for Intellectual Property
We will protect our company’s intellectual property rights and will pay attention not to infringe any third-party rights.
16. Appropriate Management of Documents
We will ensure the appropriate preparation and management of documents.
17. Protection of Confidential Information
We will protect, and we will not disclose or cause anyone to disclose confidential information, such as our company’s important information, customers’ personal information, and business partners’ information to anyone other than persons who are duly authorized to access such information.
18. Ensuring Reliability and Security of Information Systems
We will endeavor to properly manage, and secure the reliability and security of information systems in order to make use of “information,” which is our important management resource, safely and efficiently.
19. Maintaining a Sound and Safe Working Environment
We will maintain a sound and safe working environment, and we will create a vibrant workplace where good communication is provided.
20. Distinction between Public and Private; Reasonable Entertainment, and Gifts
We will not mix up public and private matters. We will behave according to our own good sense. We will not offer or receive any entertainment or gifts and the like that might lead to suspicion or mistrust.
21. Establishment of a Good Working Environment
We will endeavor to establish a good working environment where human rights are respected, and where no discrimination or harassment exists.
22. Implementation and Continuous Improvement of Responsible Business
We will be responsible for conducting our business in compliance with laws and regulations and our company’s various rules, and we will improve our business continuously.
23. Environment-Friendly Corporate Activities
We will comply with environmental legal restrictions and our company’s environmental rules, and we will conduct our corporate activities in consideration of reducing the burden on the environment.
24. Social Contribution Activities as a Corporate Citizen
We recognize that the development of society (especially a local community) will strengthen the basis of the Tokyu Group’s existence, and we will endeavor to create a good society as a corporate citizen.
Compliance Promotion Structure
(1) Compliance Officer
The officer in charge of the Internal Control Office acts as the compliance officer, and performs the following roles as the chief officer of “risk management through compliance management” at the Company.
- Formulation of Compliance Code, etc.
- Establishment of structure for “risk management through compliance management”
- Reporting of status to the Board of Directors, etc.
(2) Internal Control Office
The Internal Control Office is in charge of promoting and overseeing “risk management through compliance management,” and plays the following roles in promoting compliance.
- Ensure awareness of Compliance Code, etc., and foster awareness on compliance
- Implement surveys on the status of practice regarding the Compliance Code, etc., and make improvements
- Respond to consultations regarding the Compliance Code, etc., and respond to cases of violations of the Compliance Code, etc.
- Plan and implement training on compliance and risk management
- Monitor the practice status at each division, branch, business unit and subsidiary, etc. (implementation of audit)
(3) The Manager in Charge of Compliance/The Person Responsible for Compliance
In order to ensure the effectiveness of compliance in each department, the general manager of each division, branch and business unit, and other line managers who directly report to the President, as well as the presidents of subsidiaries are appointed as “the managers in charge of compliance,” and the general manager of the general affairs division at each division, branch, business unit, etc., the general managers of the Corporate Strategy Division and Business Administration Division and the general managers of the general affairs divisions of subsidiaries are appointed as “the person responsible for compliance.”
These managers in charge of compliance and persons responsible for compliance cooperate with the Internal Control Office in working to develop and improve the compliance structure in each department, while evaluating the status of practice regarding compliance each year, and reflecting the results of each evaluation in the improvement plan for the following year.
Education and Training of Employees
In order to ensure that our officers and employees fully understand the importance of “risk management through compliance management,” we will gradually and continuously raise awareness and conduct training, such as: (i)training for the employees in each department, with the aim of raising their awareness (organized by the Internal Control Office); (ii) personnel training to raise awareness by including lectures on compliance in level-specific training organized by the Personnel Department, etc. (organized by the Personnel Department ) and (iii) more practical voluntary training at each workplace, centered on case studies and discussions tailored to the actual situations (organized by each department).
In addition, in order to ensure that compliance awareness takes root within the Company, we conduct online learning and training upon promotions, with content that varies according to position. There has recently been an increase in the number of cases abroad in which the bribery of foreign public officials has been exposed, and it is not sufficient to pay attention only to domestic developments. As such, from FY 2016, we have introduced the overseas compliance program, which includes publication of the Compliance Code in foreign languages for overseas offices, and regulations aimed at preventing violations such as bribery of foreign public officials and cartels.
We provide a whistleblowing system, in accordance with the Compliance Consultation and Reporting Regulations, with the aim of detecting possible compliance violations early, and internally rectifying them swiftly.
Points of contact for whistleblowing have been established internally, as well as externally through a law firm. Employees (including temporary staff) can consult and report via phone, email, document or face-to-face meeting (consultations and reporting can be carried out anonymously).
We encourage our employees to consult with the Compliance Consultation and Reporting Desk when they do not know what to do, or feel even slightly that there may be a problem, on compliance issues.
In addition, at overseas bases, we have set up Overseas Consultation and Reporting Desks that support consultation requests in the official language of each country, as well as in English.
Prevention of Corruption
The managers in charge of compliance and persons responsible for compliance cooperate with the Internal Control Office in working to prevent corruption, while evaluating the status of practice regarding prevention each year, and reflecting the results of each evaluation in the improvement plan for the following year.
Basic Policy Regarding Foreign Compliance
Our Group (which includes the Company and its subsidiaries) has established the following basic policy, with a view toward preventing bribery of public officials, and the like, and other prohibited acts such as cartels, in conducting business abroad, and will promulgate this policy among our officers and employees, as well as business partners.
There is a growing risk of penalties involving huge fines being imposed on corporations and individuals, due to tighter international regulations and so-called competition laws that regulate the bribery of foreign public officials, and the like overseas, as well as acts that distort market competition. Based on this recognition, we have established the Foreign Compliance Program, which includes a top message and basic policy, with a view toward responding to such risks, and began its implementation in April 2016. For the purpose of implementing this program at overseas bases, we conducted training in FY 2018 for 49 national staff members who work locally.