Risk management and compliance

Risk management and compliance structure

We strive to promote compliance in accordance with our compliance regulation, which stipulates the compliance practice system and operations, as well as our compliance policy, which sets out a code of conduct for officers and employees. Compliance is promoted under the leadership of the Legal and Compliance Department of the Group CLO organization, which is responsible for overseeing compliance, in cooperation with each business division. The Risk Management Committee, chaired by the Representative Director, President, and Group CEO, meets quarterly with the participation of the SVP and Group CLO; the committee discusses and makes policy decisions on important matters related to compliance and anti-corruption. The committee reports not only on issues related to actual events, but also on near-miss events, and holds preventive discussions based on changes in social conditions and the business environment, thereby strengthening efforts to address compliance issues that have a significant impact on corporate value and stakeholders.We have adopted the Audit & Supervisory Committee for our corporate governance system.

Compliance training

In accordance with the annual compliance plan, we conduct training and officers and employees education programs on legal compliance and anti-corruption. In addition, based on the business environment and service content of each division, we also conduct individual training as needed on specific themes faced in daily operations to acquire the necessary compliance knowledge and raise awareness of compliance in the course of business.
As the scale of the Group organization expands, it is important that the officers and employees continuously receive appropriate programs in a timely manner. In addition to our existing compliance training by in-house instructors, we introduced an e-learning compliance training system to expand our educational and awareness-raising activities. By fostering compliance awareness among the officers and employees, we aim to further improve our corporate value so that our stakeholders can engage in business with us with peace of mind.

Internal reporting system

We have established three points of contact for internal reporting system for the early detection, correction, and resolution of legal violations and irregularities:an internal contact point, a contact point for Audit & Supervisory Committee members, and an external contact point (law firm); we have ensured that all officers and employees are aware of these contact points. In addition, the “Internal Reporting Regulations” explicitly stipulate that no disadvantageous treatment shall be given to any employee for making a report and that anonymous reports shall be accepted and kept confidential.

Anti-corruption and anti-bribery

Anti-corruption policy

In accordance with our Corporate Compliance Policy (Raksul Group Code of Conduct), we, at RAKSUL Group, pledge to take part in a fair, transparent, and free competition, continue taking actions to stay just and honest and live up to the trust society places in us. To realize this pledge in more concrete terms, we have established and published an Anti-Corruption Policy, which clearly states our basic approach to preventing bribery and the rules that RAKSUL Group executives and employees must follow.

• Anti-Corruption Policy

To prevent corrupt practices, we continuously examine, establish, and improve our anti-corruption management systems, taking into account country- and region-specific risks. The following practices are strictly prohibited:
(1) Corrupt practices such as bribery, illegal political contributions, donations, and sponsorships
(2) Providing improper financial or other benefits to customers or business partners to obtain or maintain trade or business favors
(3) Demanding or accepting financial or other benefits from public officials, customers, or business partners in exchange for business favors
Under this policy, we have established concrete internal rules regarding entertainment and business hospitality. Additionally, we have set up a compliance consultation and reporting channel to receive reports from our business partners, including suppliers. We recognize that maintaining fair and sound relationships with our business partners is essential for achieving sustainable business growth.

To ensure the effective implementation of this policy, we communicate its contents and related internal rules to all officers and employees through internal information-sharing and communication tools. Furthermore, we conduct regular internal training on legal compliance and anti-corruption measures. We also operate an internal whistle-blower system that allows anonymous reporting and ensures the protection of whistle-blowers. By raising awareness of this system, we enhance the effectiveness of our anti-corruption efforts.

Anti-Social Forces

We have established the “Rules for Eliminating Anti-Social Forces” in order to block and eliminate any relationship with anti-social forces. These rules stipulate the basic policy for blocking any relationship with anti-social forces and preventing damage, and also establishing a framework for eliminating anti-social forces. We screen our business partners, officers, and employees with regard to anti-social forces, and introduce anti-social force exclusion clauses in the business terms of our policies and contracts.

Internal Control System

Basic Policy for the Establishment of an Internal Control System

In order to ensure the appropriateness of management, improve transparency, and ensure thorough compliance, we have established a “Basic Policy for the Establishment of an Internal Control System” at the Board of Directors meeting, and are working to establish and operate an internal control system.

Implementation of Internal Audits

We have established an Internal Audit Department, which conducts regular internal audits. Based on our Internal Audit Regulations and the annual internal audit plan, the department conducts internal audits of each division, including the effectiveness of internal control systems, and reports the audit results to the Representative Director, President on a regular basis, as well as reporting on the status of internal audits to the Audit & Supervisory Board Members. In addition, the internal audit personnel regularly exchange views with the Audit & Supervisory Board Members, and the three parties share information on any audit-related issues or concerns to ensure close cooperation. The internal audit plan also calls for compliance audits (covering the implementation of the Compliance Policy and the Anti-Corruption Policy) to be conducted once every three years.

Information security

Approach to information security

As a company that handles customers’ confidential information, we consider the prevention of information security incidents to be our social responsibility. We will thoroughly manage information and aim to be a company trusted by our customers.

Security initiatives

We have established a Basic Policy for Information Security and are building an information security system.

We have established an Information Security Committee, and have acquired ISMS certification to continuously improve our information security management, as well as P Mark certification to protect personal information. In addition, we provide security training to our employees and undergo an external security audit at least once a year.

• Approach to information security (in Japanese)