Compliance

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.

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 2025, the “Compliance Committee” convened nine 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.

To assess the level of compliance awareness, we conducted an online anonymous survey of all employees in Japan and overseas in fiscal 2021 and 2024. The results of the fiscal 2024 survey show that the “need to reduce workloads,” an issue identified in the last survey, has been resolved, with a significant improvement made in awareness of the whistleblower system among others.
Going forward, we will stay committed to implementing effective measures continuously and building a more robust compliance system.

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.”
Based on this policy, we make clear our basic anti-corruption stance and continuously provide training to raise awareness among employees.
In fiscal 2025, 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 Code of Conduct Training (e-learning).
We have a system in place to keep the Compliance Committee informed about violations. In fiscal 2025, there were no violations of anti-bribery or anti-corruption rules.

The Tokyo Seimitsu Group provides various 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, we provide e-learning-based training in Japan. In fiscal 2025, 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, we provide various internal and external contact points for direct whistleblowing, 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 2025, although there were 15 whistleblowing cases, there were no compliance issues affecting our business activities.

In fiscal 2025, 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 the adequacy of our financial reporting, product quality and environmental initiatives, handling of stakeholders inside and outside the company, etc.