Tokyu Group’s Compliance
Compliance management — a corporate management approach based on ethics and compliance — is an essential part of improving corporate value and remaining the trusted brand of choice for our customers. At Tokyu Construction we have set our own Guidelines for Action/Compliance Code based on the Tokyu Group Compliance Guidelines and have actively worked to ensure compliance. We also strive to prevent risks from materializing and quickly respond to risks that do materialize through the risk management system.
Basic Approach to Compliance
We consider following corporate ethics and laws and regulations to be non-negotiable and the most fundamental part of compliance. To completely eliminate violations caused by lack of knowledge or awareness, we have established the Guidelines for Action/Compliance Code and are providing thorough employee training to instill them in each and every employee in order to make sure that compliance is firmly imprinted in Tokyu Construction’s corporate DNA.
Guidelines for Action / Compliance Code
1. Focus on risk management
We recognize that risk management is essential to improving our corporate value and will establish processes to manage risks properly.
2. Securing safety
We recognize that safety comes first under all circumstances in which we provide products and services, and will implement initiatives to secure safety.
3. Business operations based on customer needs
We will properly identify the needs of our customers and provide high-quality technology in our business processes, including planning, design, and construction. We will also make sure that our customers fully understand and agree with the contents and features of our products and services. We will respect the wishes of our customers, and conduct our business operations in good faith.
4. Providing high-quality designs and construction products
We will comply with the Building Standards Act and other laws and regulations, as well as our internal standards regarding product quality, in order to provide reliable, high-quality designs and construction products for the satisfaction of our customers.
5. Appropriate response to feedback from customers and local communities
We will faithfully and promptly respond to various feedback from our customers and residents in the local communities of our business sites. We will make use of such feedback to improve our business operations and services.
6. Fair and Transparent Decision-Making
We will make decisions based on appropriate and accountability in compliance with laws and regulations, and our company rules.
7. Protection of corporate assets
We will carefully handle our corporate assets, which are the source of our corporate value.
8. Timely, Appropriate, and Fair Information Disclosure and Public Relations Activities
We will conduct public relations activities and disclose information to all of our stakeholders in a timely, appropriate, and fair manner in order to gain their understanding and receive the right evaluation.
9. Prohibition of Insider Trading
We will never commit any insider trading nor conduct questionable trading of shares.
10. Securing compliance and fair trade
We will understand the intent of laws and regulations, and will not engage in illegal or unfair trading.
11. Refusal of relationship with anti-social forces
We will never engage in nor accept any transactions or other relationship with anti-social forces. If a problem occurs, we will stand firm as a company and take a tough stance.
12. Optimal procurement activities
We will provide fair and equitable business opportunities to suppliers and other business partners, make sure that our vendor selection process is fair and our procurement process is the most suitable.
13. Appropriate management of rules
We will establish effective company rules to address performance efficiency and risks in conducting our business, and keep our officers and employees fully informed of them.
14. Appropriate business operations and internal control
We will conduct our business using appropriate procedures and at the same time implement internal control according to our business operations.
15. Respect for and protection of intellectual property
We will respect intellectual property including that of other entities and rights to it, and protect our company’s intellectual property.
16. Appropriate Management of Documents
We will ensure the appropriate preparation and management of documents.
17. Protection of confidential information
We will strictly protect confidential information, such as customers’ personal information, business partners’ confidential information and our company’s important information, and prohibit its disclosure to anyone other than persons who are duly authorized to access such information.
18. Ensuring security and reliability of information systems
We will properly manage and ensure the security and reliability of our information systems in order to safely and effectively use information, which is our important management resource.
19. Maintaining a safe and healthy working environment
We will maintain a safe and healthy working environment, and will create a vibrant workplace with good communication.
20. Separation of business and personal; reasonable gifts and entertainment
We will act with common decency and separate our business and personal matters. We will not offer or accept any gifts or entertainment that may be questionable or discredit the company.
21. Creating a good working environment
We respect the human rights of our workers and will create a good working environment free of discrimination or harassment.
22. Responsible business implementation and continuous improvement
We will responsibly conduct our business in compliance with laws and regulations and our internal rules, and will continuously improve our business operations.
23. Reducing environmental impact of our corporate activities
We will reduce the environmental impact of our business activities as well as comply with relevant environmental laws and regulations and our company’s environmental rules.
24. Contributing to community development
We recognize that developing local communities and society as a whole strengthens the basis of the Tokyu Group’s existence. We will contribute to creating a better society as a corporate citizen.
Compliance 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.
- Formulate the Compliance Code
- Establish the structure for risk management through compliance management
- Report the status of compliance programs to the Board of Directors
(2) Internal Control Office
The Internal Control Office performs the following roles related to compliance.
- Ensure that all employees are fully informed of the Compliance Code, and raise compliance awareness
- Conduct surveys on employees’ adherence to the Compliance Code, and make improvements
- Have consultations on compliance matters, and respond to violations of the Compliance Code.
- Plan and implement training on compliance
- Implement internal audits to assess the state of practice at each division, branch, business unit and subsidiary
(3) Manager and Staff in Charge of Compliance
In order to ensure compliance at 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 managers in charge of compliance, and the general manager of the general affairs division at each division, branch, business unit, 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 staff in charge of compliance.
These managers and staff in charge of compliance cooperate with the Internal Control Office to develop and improve the compliance structure at each department, evaluate their practices each year, and reflect the results in the improvement plan for the following fiscal year.
Compliance Education and Training
To deepen the understanding of our officers and employees regarding the importance of risk management through compliance management, we are continuously conducting the following training programs: (i) group training to raise awareness, including compliance lectures in level-specific training; (ii) voluntary training centered on case studies and discussions tailored to the actual situations in each workplace; and (iii) ongoing e-learning sessions to foster compliance awareness among all employees.Additionally, we conduct leadership training for compliance officers in each department to ensure the effectiveness of compliance at each workplace. Since FY2020, we have also implemented e-learning for local employees overseas to strengthen compliance awareness abroad.
Whistleblowing System
Based on our Compliance Consultation and Reporting Regulations, the company has a whistleblowing system in place to detect potential compliance violations early-on and promptly make corrective actions. Whistleblowing contact points have been established both internally and externally through a law firm. Directors, advisers, employees, part-time employees, temporary workers, retirees, and employees of the Company or any of its subcontractors, as well as the employees of any joint ventures of the Company can use the whistleblowing system for consultation or to report problems, by telephone, email, postal mail, or in person.
The system allows consultations or reports to be made anonymously. It prohibits any disadvantageous treatment of the reporter, thereby clearly protecting the individual. In FY2023, there were 32 cases of reports and consultations.
At offices outside Japan, we have set up Global Compliance Consultation and Reporting Desks that support consultation requests in English and the official languages of each country.
Prevention of Corruption
System
The managers and staff in charge of compliance cooperate with the Internal Control Office to prevent corruption, evaluate prevention practices each year, and reflect the results of each evaluation in the improvement plan for the following year.
Basic Policy on Global Compliance
The Tokyu Construction Group (including the Company and its subsidiaries) has established the Global Compliance Program with the aim of addressing the growing risks associated with large fines and other penalties imposed on corporations and individuals due to tighter international regulations, including competition laws that prohibit bribery of foreign public officials and acts that distort market competition when conducting business abroad. Based on this recognition, we developed a Global Compliance Program that includes a message from the president and a basic policy, and began its implementation in April 2016.
To promote the penetration of this program, we conduct training for local staff working at overseas offices, and since FY2020, we have implemented overseas compliance education through e-learning. In addition, we established Global Compliance Consultation and Reporting Desks at our offices outside Japan that offer support in English and the official languages of each country.