Compliance System
Basic Approach
SCSK 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 corporate citizens to be 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
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 (or "speak up" system) for quickly resolving compliance violations and preventing such violations from occurring by enabling employees of the SCSK Group and partner companies to report and consult on problems.
Contact Points and Whistleblowing Methods
Whistleblowers may report a problem to any of the three following contact points by email or another method at their own discretion:
- (1) Chair of Compliance Committee
- (2) Audit and Supervisory Committee
- (3) Outside lawyer (reports may be anonymous)
Regardless of the point of contact, the privacy of whistleblowers and other related parties is strictly protected along with the confidentiality of reported matters. Guarantees are in place to ensure the whistleblowers are not subjected to unfair treatment.
Investigation of Matters
All reports and consultations are handled promptly by the contact points. If necessary, investigation is conducted in cooperation with relevant departments based on policies established by the Chair of the Compliance Committee.
The results of investigations are promptly informed to the whistleblower. The results of investigations and details of corrective measures are also reported to the Board of Directors, the Audit and Supervisory Committee, the Compliance Committee, and similar entities.
Disclosure of results
In FY2022, seven speak-up cases were received by the SCSK Group as a whole. Under the leadership and direction of the Chair of the Compliance Committee, each case was investigated in cooperation with the relevant departments and, based thereon, corrective and other appropriate measures were taken. The investigation results were communicated to the whistleblowers.
Aside from the whistleblower system, we have created hotline on a permanent basis, which responded to 78 consultations.
Fair Transactions
The SCSK Compliance Manual clearly stipulates that the SCSK Group 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, setting rules on anti-bribery, political donations, and the handling of antisocial forces.
Education and Training
It is essential for each employee to be able to make correct decisions and actions in compliance with the law, regardless of whether relating to business or not. Toward that end, we provide information on compliance as well as various forms of compliance training, including group training for new employees and newly appointed managers, e-Learning, and compliance meetings (group discussions on compliance). In regard to important applicable laws and regulations, we post our Compliance Manual and other information pertaining to those laws and regulations on each company’s intranet portal site to foster greater awareness of compliance.
