Foreign Compliance

Foreign Compliance

Message from the President
about the Basic Policy for Foreign Compliance

Our Group states our mission that “We will help each person in the relevant community to realize his or her dream by creating a safe and comfortable living environment,” and also states that the meaning of our Group’s corporate existence is to fulfill our social responsibilities, and to provide safety and security to citizens through the performance of our business activities.

In order to build “trust” as a basis of the business of our Group, it is essential to ensure safety and product quality, environmental consideration, as well as highly-transparent business processes and risk management in compliance with statutes and rules, and fair and correct disclosure of corporate information. Therefore, our Group has established the Compliance Code consisting of 24 items, and requires the officers and employees of our Group inside or outside Japan to behave in compliance with the Compliance Code.

The number of cases of bribery of public officials or the like and actions distorting fair competition including cartels being exposed is increasing globally. Countries into which our Group has entered are said to have a high occurrence of such risks. Therefore, the importance of compliance and risk management in foreign countries is rapidly increasing. Such violating acts will cause the relevant company or person to be punished.

Moreover, such violating acts will corrupt the morals of the public officials or the like in the relevant country, will discourage the promotion of free competition in the economy, and will hinder development of the entire society. Therefore, such violating acts are wrongdoing contrary to the meaning of the existence of our Group.

For that reason, our Group will endeavor to conduct overseas business activities with a strong will “not to choose any unfair measures to obtain profit, but in any case to maintain legal compliance, and not to permit anyone to get involved in any unlawful act for any reasons.”

June 1, 2019

President and Representative Director

Mitsuhiro Terada

Basic Policy for Foreign Compliance

Our Group (which means our company and its subsidiaries) has established the following basic policy in order to prevent bribery of public officials or the like and violations of acts such as a cartel in conducting business in a foreign country. We will promulgate it among officers and employees of our Group and our business partners.

  1. Our Group will comply with the Japanese Unfair Competition Prevention Act, U.S. Foreign Corrupt Practices Act (FCPA), United Kingdom Bribery Act (UKBA), and other law regulating bribery in the relevant countries; and it will not offer any benefit to foreign public officials or the like in order to obtain profit unlawfully.
  2. Our Group will comply with the Japanese Anti-Monopoly Act, the U.S. Sherman Act, and any other statutes regulating private monopoly, unfair trading methods, and improper transactions of other relevant countries; and it will conduct business activities in accordance with the principles of fair market competition.
  3. Our Group will develop the Foreign Compliance Program (the “Program”) under the initiative of top management regarding compliance and risks in overseas business activities, and it will establish and maintain a mechanism to comply with the laws and regulations set forth above through operation of the Program.
  4. Our Group will include establishment of an internal system to manage and operate the Program, develop a consultation and whistleblowing system, education system, internal audit system, and other systems in the Foreign Compliance Program; and it will make the program effective.
  5. Our Group will devote management resources necessary to manage and operate the Foreign Compliance Program, and it will evaluate and review the mechanism for the program regularly.
  6. Our Group will not place an order with any company that violates the laws and regulations set forth above.

April 1, 2016