Approach to Compliance

1. Setting up the Compliance Committee

The Shindengen Group considers compliance with laws and regulations, such as Competition Laws and Bribery Prevention Laws, to be one of its top priorities. The establishment and timely improvement of effective compliance management procedures and standards is essential. Regular compliance training, as well as keeping up to date with the latest laws and regulations ensures Shindengen can meet its compliance obligations. On October 1, 2015, the Compliance Committee was established with Shindengen’s President as the Chair, and it aims to support the establishment, implementation, and improvement of compliance management at domestic and overseas Group companies.
Committee actions include:

Revised Shindengen Group Guideline for Action

In April 2016, we renewed the “Shindengen Group Guideline for Action” adding in terms regarding the observance of competition laws and bribery regulations. We sent this revised guideline to all employees of Shindengen Group companies under the name of the chairperson and also updated the website, and overseas Group companies translated these the guideline for action into the local languages of their host countries to ensure that all are thoroughly informed and educated.

Competition Law

As the main promotion body, the Compliance Committee continually conducts PDCA cycles in an effort to build a compliance program for Competition Laws. As for specific actions, the committee established antitrust law compliance rules, rules for interacting with competitor companies, and a manual for applying for penalty reductions and exemptions (2016); provided cooperative support to overseas group companies on preparing corresponding rules (2017); and regularly provides in-house education and training to sales departments. As for recent actions, the Compliance Committee shares information regarding the key points of the 2019 revised Antitrust Law that came into effect in December 2020 and is working to revise in-house rules in response to the new penalty system.

Bribery Prevention Actions

As for bribery prevention actions, we provided in-house education and training to sales departments while preparing the in-house rules and manuals (including bribery prevention rules and rules related to providing gifts to foreign government officials), similar actions to those taken for the Competition Laws.

Initiatives for the Personal Information Protection Law

•As for action on the Act on the Protection of Personal Information, the Compliance Committee takes the lead and works to respond to relevant laws and regulations in Japan and overseas.
•As for our response to date to Japan’s Act on the Protection of Personal Information, we conducted a fundamental adjustment related to the protection of personal information, including revising our privacy policy and in-house rules and taking stock of the personal data in our possession. In addition, we continually conduct annual in-house education and training for departments that handle personal information.
•As for our action on overseas data protection laws and regulations, we responded to the EU’s General Data Protection Regulation (GDPR) by posting privacy notices on our website, responding to rules on international transfers of personal data outside the European Economic Area (by concluding Shindengen Group standard contract clauses (SCC)).
•As for recent actions, the Compliance Committee shared information regarding the main details of the revisions to the 2020 revised Act on Protection of Personal Data. Going forward, we will continue revising privacy policies and in-house rules in line with the revisions and establishing in-house rules for when personal data is leaked while paying attention to guidelines released from the Personal Data Protection Committee.

2.Whistleblowing System and Internal Reporting on Corporate Compliance

To ensure the Shindengen Group operates at the highest legal and ethical standards, an internal whistle-blowing system has been established. The system aims to provide a safe communication channel for employees to report and respond appropriately to illegal and/or unethical conduct. A whistleblower hotline has been established, with domestic Group companies using Shindengen’s Internal Audit Department and an external lawyer as communication channels for reporting and counseling. Overseas subsidiaries establish their own in-house channels and use Shindengen’s Internal Audit Department as a communication channel for reporting and counseling.

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