Compliance

Compliance

Basic Approach

The company views compliance as observing laws and regulations, and acting with a high sense of ethics within the norms of society. Based on its corporate philosophy and Code of Conduct, SCSK considers acting sincerely and appropriately as members of society and the company as the most important principle for director and employee conduct. Each individual director and employee is responsible for his/her own actions based on the concept of compliance, and strives to produce results that fulfill the social responsibility of the entire company as an organization.

Structure and System

System to Promote Compliance

2017_compliance_01

Following our basic approach to compliance, we have established Compliance Rules and compiled a Compliance Manual as well as built an organizational structure for compliance. We have set up a Compliance Committee to follow through with our commitment to compliance. This committee determines and revises company-wide policies on compliance, maintains and manages the compliance system, coordinates with relevant departments, monitors implementation status and shares information.

Whistleblower System

We have established a whistleblower system for quickly resolving compliance violations and preventing such violations from occurring. This system enables employees of Group companies or partner companies that notice a problem to report it directly to the Compliance Committee, Audit and Supervisory Committee, or a designated attorney at law. The privacy of persons filing a report and related parties is protected along with the confidentiality of reported matters. Guarantees are in place to ensure persons who report a problem are not subjected to unfair treatment. Reports are handled appropriately and are fed back to whistleblowers.

Education and Training

Recognizing that employees are the foundation of compliance, we provide various forms of compliance training so that regardless of the situation the correct decision and action are taken following rules and regulations on compliance. We have compiled a Compliance Manual that contains detailed commentary on particularly important laws and regulations. We also strive to foster greater awareness of compliance through our in-house website and other means.

Fair Trading

Basic Approach

The SCSK Compliance Manual clearly stipulates that we must ensure fair transactions as specific rules about compliance. Its standards include a Code of Business Activities, which sets forth requirements for compliance with the Anti-Monopoly Act and prohibition of unfair competition. These standards support the development of commercial relationships based on trust with our suppliers through fair and free competition.

The manual also outlines corporate ethics required for fair operating practices in its Code for Employees as Members of Society, which includes rules against corruption and rules concerning political donations and stresses the mportance of resisting organized crime.