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In order to ensure management in compliance with laws and regulations, the HTS Group has put in place a system to clarify compliance functions and set a compliance basic policy, including matters concerning anti-corruption, to be observed by all officers and employees, to ensure thorough compliance with laws and regulations, company rules, and corporate ethics. We have also established "HTS Group Code of Conduct" defining how all officers and employees should act in their daily operations as it is vital for the entire group not only to comply with laws and regulations, including anti-corruption laws and competition laws, but also to act in accordance with corporate ethics in order to meet trust and expectations of the society. Furthermore, we ensure thorough compliance to foster a corporate culture that values corporate ethics and compliance by actively providing compliance trainings and awareness projects, including e-learning, companywide group seminars and compliance meetings.
At the HTS Group, we have an appointed compliance officer who oversees the compliance activities and initiatives of the entire group. In addition, the sales operations department, domestic group companies and overseas regional headquarters, all have an appointed compliance supervisor in place as we work to develop and strengthen the compliance system. The Compliance Officer reports to the President regarding the status of compliance, including status of anti-corruption-related matters (bribery or corrupt practices, conflict of interest, insider trading, money laundering, etc.) and competition law, within the Group. The Compliance Officer also regularly reports to the Auditing Committee, so the Company's compliance measures are under the supervision of the Board of Directors.
We hold Compliance Meetings for the purpose of information sharing and opinion exchanges relating to compliance targeting persons in charge of compliance in Group companies, for familiarization with compliance-related measures including matters concerning anti-corruption and thorough prevention of scandals. (domestic: 2 times/year, overseas: once overall, once in area unit)
To build a solid corporate culture that will not accept any compliance violations, we provide rank-based group trainings for compliance education targeting new employees, young employees, new assistant managers/managers, new directors of domestic group companies, in addition to e-learning for all employees including officers, for the purpose of deepening understanding of anticorruption laws, warehousing business law, etc. The Legal Department also implements training sessions travelling around sites.
|Number of attendees of compliance education *(FY2020)||218|
*Excluding e-learning attendees, only training conducted by the HTS Legal Department
|Number of attendees for Code of Conduct e-learning*(November 2019 - February 2021 results)||153,118 (total)|
*Number of training items: 17, Number of target companies: 68 (HTS, domestic group companies, overseas group companies)
Since 2019, October of each year has been designated "HTS Group Code of Conduct Month," and we have been striving for thorough compliance with laws and regulations in the Group as a whole and establishment of corporate ethics from the example of top leadership.
|Dissemination of Top Message||All employees*|
|Familiarization through in-house newsletters|
|Dissemination of message from the Top in the four overseas regions, each area headquarters|
|Dissemination of message from the Top in the group companies in domestic|
|Case study of compliance in general|
|Acquisition of written pledge relating to the observance of codes of conduct||All managers in Japan and abroad|
*20 domestic Group companies including HTS, 61 overseas Group companies
The Group has established an whistleblowing system, which allows employees and other concerned parties to report illegal and/or inappropriate actions with a sense of security in order to detect and correct them early on. In addition to the internal points of contact for reporting, we have also established a system for reporting to an external lawyer as an external point of contact. This system is available to all workers at the HTS Group, including directors, full-time staff, part-timers and temporary workers at both the Company itself and all of its group companies as well as employees of suppliers to HTS or its Group companies. The HTS Group protects the personal information of the caller, and ensures confidentiality of the report, as well as prohibiting any disadvantageous treatment related to the issue, in order to protect whistleblowers.
To further improve internal awareness of "HTS Group In-company Compliance Reporting System", posters for dissemination were prepared in 20 languages and posted in each office.
|Method of reporting|
|The following points of contact are equipped with a system for reporting by sealed letter, e-mail, website entry, etc.|
|Information that can be reported|
In June 2021, we become a registered company of "Whistleblowing Compliance Management System certification (self-declaration of conformity registration system)" under the jurisdiction of Consumer Affairs Agency of Japan. "Whistleblowing Compliance Management System certification (self-declaration of conformity registration system)" is a system introduced by the Consumer Affairs Agency in February 2019 to promote the appropriate maintenance and operation of the whistleblower system, which is an important element of corporate internal controls and corporate governance.
We will continue to improve the development and operation of our whistleblowing system and further strengthen our compliance system so that we can live up to the trust of our customers and society.
*Certification standards for whistleblower systems based on the "Guidelines for Private Enterprises Regarding the Development and Operation of Internal Reporting Systems Based on the Whistleblower Protection Act" (December 9, 2016, Consumer Affairs Agency)
The numbers of violations of anti-corruption and competition laws and regulations in FY2020 are as follows.
We stipulate in the HTS Group Code of Conduct that political contributions can only be made if the philosophy of the political organization or politician is in line with our corporate philosophy. When making contributions, we comply with the Political Funds Control Act and other related laws and regulations.
|Amount of political contributions in FY2020 (thousands of yen)||1,760|
The following is compliance data including number of compliance training conducted, number of whistleblowing reports and consultation, etc.