Compliance

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.

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 2023, the “Compliance Committee” convened 11 times.

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.

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. The next survey is scheduled to be conducted in 2024 as a compliance awareness survey for all Group companies.

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 2023, we conducted training for all officers and employees of Group companies on how to respond when offered entertainment and gifts. No violations were found in fiscal 2023.

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 2023, 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.

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.

In fiscal 2023, although there were nine whistleblowing cases, there were no compliance issues affecting our business activities.

In fiscal 2023, 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.