Mechanisms Supporting Our
Compliance System

• Reporting and Consultation System

  • When any one of us discovers an action that may violate the Compliance Charter or Code of Conduct, we shall promptly report to and consult with our supervisor and/or relevant department, even if we are not sure whether the action actually violates the Compliance Charter or the Code of Conduct.
  • Supervisors and others involved shall constantly strive to create a facilitative environment for such reports and consultations from subordinates. When they receive a report or consultation, they shall promptly report it to the department head through the reporting line, except in cases where the person making the report or consultation wishes to report to a different party.
  • We shall use the Compliance Hotline or Harassment Helpline when we are unable report to or consult with our supervisors or others involved.
  • We shall be cooperative with investigations when asked to do so.
  • We shall not tolerate any prejudicial treatment or retaliation against anyone who has made a report or consultation in good faith or cooperated in an investigation because of that fact.
  • We shall not file a report or engage in a consultation for the purpose of defaming or slandering any person or for any other improper purpose.

• Response Policy

  • If a department head or other responsible party becomes aware of a compliance issue, they shall promptly notify the Compliance Department of FUSO GROUP Holdings Inc. (“the holdings company”) of the issue.
  • Upon receipt of a report or consultation, the holdings company’s Compliance Department will investigate and respond to the report or consultation in cooperation with relevant departments and outside experts, as appropriate, based on the urgency and nature of the issue and given consideration to protecting the person who made the report or consultation.
    If the problem is deemed urgent and serious, it will be immediately reported to the President of the holdings company.
  • If, as a result of the investigation, a compliance issue is identified, corrective and recurrence prevention measures will be implemented as appropriate.

• Disciplinary Committee

  • If, as a result of an investigation or other fact-finding process, it is determined that the matter subject to the report or consultation could be grounds for disciplinary action, the Board of Directors of the involved company or companies will consult with the Disciplinary Committee, which is established within the holdings company. The board or boards in question will consider the committee’s recommendations and determine whether or not disciplinary action is necessary and what the disciplinary action should be.
  • The committee will certify the fact of the case and discuss the applicability of disciplinary action, and make a recommendation to the Board of Directors of the company or companies in question on whether or not disciplinary action is necessary and the details thereof. This disciplinary system is designed to ensure fairness and impartiality by thoroughly verifying facts and providing opportunities for involved parties to explain the facts of the case.

• Compliance Committee

  • The Compliance Committee meets on a regular and ad-hoc basis as a permanent body to determine compliance measures for the entire FUSO GROUP.
  • This committee determines priority measures for the Group from a bird’s-eye view of the organization, including preventive measures and measures to prevent recurrence. This is done with reference to reports from Group companies, summaries of reports and consultations received via the Compliance Hotline and Harassment Helpline (personal information will not be provided without the consent of the person reporting or consulting), disciplinary information, and industry and social trends.

• Education and Training

  • In order for the compliance system to function, and in order to maintain and improve this system, it is essential that key personnel take the initiative and that the system is supported by the awareness and knowledge of employees.
    The FUSO GROUP has established and operates an education and training system for compliance that focuses on ongoing development.
  • We shall always be earnest in undertaking compliance education and training, striving to prevent compliance violations.