Basic Policy
Ensuring compliance requires that each and every employee conduct themselves with discipline as members of the organization, guided by our corporate philosophy, and fulfill their social responsibilities. Based on this belief, we are committed to fostering a strong culture of compliance—one that emphasizes not only adherence to laws and contracts but also conduct guided by high ethical standards aligned with societal norms.
Compliance Structure
As human capital management and product quality and safety are two of the materiality issues identified, the management structure places particular emphasis on compliance with respect to employee occupational health and safety and cyber security/data security.
In addition, to discuss specific issues related to employees’ health and safety and execute business, the Company has built an organizational structure with the Health and Productivity Committee and the Office Environment Committee set up under the Sustainability Council, the Safety Committee under the Office Environment Committee and the mandatory Health Committee under the Health and Productivity Management Committee. The Health and Productivity Management Committee seeks the involvement of occupational health physicians and employee representatives to plan, formulate, and implement measures that contribute to the maintenance and improvement of workers’ and their families’ physical and mental health, and as a result, to the improvement of productivity.
Further, to manage risks associated with cyber security and data security, the Company has appointed Chief Information Security Officer (the “CISO”), and has set up the Information Risk Management Committee as an advisory body to the CISO, which consists of representative members from each business division, including the division heads, to build a structure whereby it collects information across the Company to resolve issues.
Major Initiatives
Fair Competition
We have established a basic anti-corruption policy and take strict measures to prevent corruption, including the offering of bribes to public officials. We are also committed to complying with laws and regulations concerning fair competition and business transactions, including the Anti-Monopoly Act and the Subcontract Act (Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors).
Ensuring Effectiveness in Compliance with Laws and Regulations
In accordance with the Internal Reporting Regulations, we have established an internal reporting desk operated by an external third-party lawyer as the contact person. In the event of receiving a report of a compliance violation or other incident, we have put a system in place to properly investigate the matter and implement corrective measures to the relevant departments. In addition, the Internal Audit Office, consisting of the head of the Internal Audit Office and seven staff members, conducts internal audits with the aim of enhancing compliance as a company, let alone contributing to the improvement of business performance and the safeguard and utilization of assets.
Implementation of Compliance Training
With the aim of strictly prohibiting insider trading that violates the Financial Instruments and Exchange Act, we have established Rules for Preventing Insider Trading and strives to ensure thorough information control. With regard to trading of shares by the Simplex Group’s officers and employees, we have established strict periods during which trading is prohibited, and put in place approval procedures and other procedures for trading, as well as training and testing for all employees and business partners.
In addition, as part of efforts to prevent bribery and other corrupt acts and excessive business entertainment mainly against domestic and foreign public officials and deemed public officials, we have established a reporting and approval system and conducts anti-corruption training for our employees.
Business Development Mindful of Human Rights
We develop our business mindful of human rights. In doing so, we have established a basic human rights policy that sets priority issues based on the results of analysis of the types of human rights that could pose a risk of serious human rights violations in the Group's business activities, as well as the severity of the assumed risk of human rights violations. Please refer to the Sustainability website for details of the Simplex Group Basic Policy on Human Rights.
Efforts to Eliminate Antisocial Forces
We take a resolute stance against antisocial forces and will immediately end any relationship with them as one of our basic policies. In accordance with the Rules for Elimination of Antisocial Forces and the Implementation Guidelines for Background Check for Relationships with Antisocial Forces, we have put in place a system to eliminate transactions and other relationships with antisocial forces. With respect to our business partners, we perform procedures to confirm that they have no relationships with antisocial forces prior to starting business with them and on a regular basis as well. In addition, candidates for officers are also subject to the same procedure prior to submitting a proposal for election to a general meeting of shareholders. We also confirm with employees that they have no relationships with antisocial forces and require them to submit written pledges.