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 Company’s vice president. 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 2022, the Compliance Committee convened seven times.

Compliance Awareness Survey

The Group conducts a Compliance Awareness Survey to confirm employee awareness and the status of compliance and to reflect survey results in future initiatives.

FY2021 Questionnaire-based Survey

In fiscal 2021, the Company conducted an online, anonymous survey of all employees in Japan and overseas, and is working to resolve issues that came to light.

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

Need to reduce workloads related to goal setting and amount of operations

Anti-bribery and Anti-corruption

In January 2020 the Tokyo Seimitsu Group announced its Anti-Bribery and Anti-Corruption Policy that follows the provisions of the ACCRETECH Group Code of Conduct. In fiscal 2022, no violations were found.

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 2022, 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 2022

Number of attendees: 2,974

Number of attendees at Group companies including overseas subsidiaries: 1,795

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, 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 meetings.
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 accepted or rejected 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 2022, although there were eight whistleblowing cases, there were no compliance issues affecting our business activities.

Whistleblower System

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, etc.

Actions that cause 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 2022, 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.