Compliance
The Tokyo Seimitsu Group complies with laws and social norms and acts with integrity and ethics to meet the expectations of all its stakeholders. To this end, we have established the “ACCRETECH Group Code of Conduct,” which sets forth principles of conduct based on our corporate philosophy and the code of conduct that all executives and employees should adhere to. Through this code, we are working to instill and establish an awareness of corporate ethics among the Group’s executives and employees.
Compliance Management Structure
The Company has established the “Compliance Committee,” which is chaired by the Head of Administration Company. This committee assigns compliance officers and compliance managers at the Company and each subsidiary.
Compliance Committee
The Compliance Committee engages in reporting and deliberation concerning compliance measures and their implementation status, including revision of the “ACCRETECH Group Code of Conduct,” enactment and revision of regulations, and planning for education and training related to compliance. In the event of violation of or potential conflict with laws and regulations, the committee promptly issues a report to the Board of Directors and Audit and Supervisory Committee and discusses response measures and recurrence prevention measures.
In fiscal 2024, the “Compliance Committee” convened 7 times.
Compliance Awareness Survey
The Group conducts a “Compliance Awareness Survey” via a questionnaire to confirm employee awareness and the status of compliance and to reflect survey results in future initiatives.
Questionnaire-Based Survey
In fiscal 2024, the Company conducted an online, anonymous survey of all employees in Japan and overseas. The results show that, of the issues identified by the last survey, the “need to reduce workloads related to goal setting and amount of operations” has been resolved and that many improvements have been made in terms of awareness of the whistleblower system among others. We stay committed to measures to ensure compliance.
Issues Brought to Light by the Compliance Awareness Survey
Need to reinforce efforts related to the compliance system
Need to strengthen efforts to eliminate harassment and discrimination
Need to enhance efforts to increase awareness of the whistleblower contact point
Need to improve the organizational climate, including communication
Anti-Bribery and Anti-Corruption
The Tokyo Seimitsu Group created an “Anti-bribery and Anti-corruption Policy” in January 2020, based on the action guidelines set forth in the “ACCRETECH Group Code of Conduct.” We make clear our basic anti-corruption stance and provide training to raise awareness among employees. In fiscal 2024, we trained employees on “Compliance with Laws and Regulations and Social Norms,” “Fair and Sincere Business Activities,” and “Entertainment, Gifts, Donations and Bribery” in the ACCRETECH Group Company Code of Conduct Training (e-learning). Also, we keep the Compliance Committee informed about whether any violation has been found. In fiscal 2024, there were no violations of anti-bribery or anti-corruption rules.
Anti-Bribery and Anti-Corruption Policy
Compliance Education
The Tokyo Seimitsu Group provides varied educational opportunities to enhance knowledge of compliance and to maintain and improve the level of compliance awareness.
Along with “new employee training,” “training for managers,” and other opportunities for level-specific training, the Company has introduced an e-learning-based training mechanism in Japan. In fiscal 2024, we conducted Compliance education, including on the “Accretech Group Code of Conduct” (an ongoing training theme) for all relevant personnel.
In addition, we report regularly to the “Compliance Committee” on compliance-related training plans and results.
Accretech Group Company Code of Conduct Training in Fiscal 2024
Number of participants: 3,287
（Consolidated：1,414 Group：1,873）
Participation rate: 100%
Whistleblower System
The Group has introduced a whistleblower system to facilitate reporting and consultation on infractions of laws and regulations, human rights violations, harassment, corrupt practices such as bribery and other illegal transactions, and other inappropriate behavior. In addition to an employee’s superior, the organization provides various internal and external contacts for direct reporting, including Compliance Committee members, the secretariat, the Personnel Counseling Department, external lawyers, external directors, and directors serving as Audit and Supervisory Committee members.
We ensure the anonymity and protection of privacy of whistleblowers, and take care to prevent them from disadvantageous treatment. The content and handling of whistleblower reports are reported and deliberated in “Compliance Committee.”
In August 2022, Whistleblower System Regulations were revised as follows.
Expanded the scope of whistleblowers in line with the “Whistleblower Protection Act”
Clarified that anonymous reports will not be rejected to accept based on the fact that they are anonymous
Revision made which requires the whistleblower contact as well as all parties involved in the investigation to keep matters confidential
Clarified the prohibition of the provision of false information, slander, or other improper actions by persons requested to cooperate in the investigation
In fiscal 2024, although there were seventeen whistleblowing cases, there were no compliance issues affecting our business activities.
Internal Reporting Regulations
1.
Objectives
2.
Whistleblower contact point
3.
Internal Reporting Methods
4.
Protection of Whistleblowers
5.
Protecting the Identities of Whistleblowers
6.
Prohibition of Whistleblowing for Improper Purposes
7.
Investigations
8.
Cooperation in Investigations
9.
Protection of Persons Involved in Investigations
10.
Corrective Action
11.
Penalties
12.
Explanation of Investigation Results
Internal Reporting Regulations
Whistleblower System
Actions that Can be Reported or Consulted on
Any action that endangers the safety or health of employees, business partners, or other stakeholders
Actions that cause deterioration or destruction of the local environment
Serious violations of the Company’s Code of Conduct, compliance regulations, employment regulations, or other Company rules
Various types of harassment
Other violations of laws and regulations, inappropriate acts, or acts contrary to social justice
Concealment, destruction of evidence, or leakage of information, related to any of the acts listed in the preceding items
Compliance Status
In fiscal 2024, evaluations conducted through internal and external audits found no illegal behavior, legal violations, compliance violations, or other problems that could affect business activities, with regard to adequacy of financial reporting, product quality and environmental initiatives, handling of stakeholders inside and outside the Company, and other matters of the Tokyo Seimitsu Group.
Environment・Society・Governance
