The Hankyu Hanshin Holdings Group aims to be a trusted and admired group of companies by meeting the expectations of all stakeholders. The Group believes that compliance-focused management is a prerequisite for achieving this goal.
1. Systematic Compliance Measures
The Company has established the post of Compliance Officer within the Personnel Office of the General Affairs Division as part of efforts to strengthen compliance on a Groupwide basis. To this end, the Company has implemented the following three core measures:
Issuance of Compliance Handbook
In an effort to improve compliance awareness, the Compliance Handbook makes it known to all officers and employees of the Group that the Company will not tolerate any violation of laws and regulations or social norms, or betrayal of customer trust. Among other topics, the handbook also presents examples of compliance issues that could easily happen.
Establishment of the Corporate Ethics Consultation Desk (Dedicated Internal Whistleblower Hotline Based on the Whistleblower Protection Act)
We have established a consultation desk that enables the all officers and employees of the Group and its corporate business partners to consult and report on any suspected or known violations of laws, regulations and other rules, as well as unethical conduct in the course of day-to-day operations. Sixty-nine reports were received in fiscal 2023 from throughout the whole Group.
We are working to promote compliance on a Groupwide basis by setting up compliance promotion offices at major Group companies, as well as appointing compliance leaders at other companies.
2. Safeguards against bribery and other corrupt practices
Outlined below is our policy for combatting bribery and other corrupt practices.
Preventing Bribery and Other Corrupt Practices
All officers and employees of Hankyu Hanshin Holdings Group shall comply with all applicable laws in force in the countries where they operate and shall work to prevent corrupt practices. As used here, “corrupt practices” means practices in which officers or employees abuse the power entrusted to them to gain an illicit advantage or to commit an act that is contrary to law or ethical standards. Examples of corrupt practices include bribery, unfair trade practices (including abusing a superior bargaining position to exploit a weaker party), and insider trading. Officers and employees of Hankyu Hanshin Holdings Group shall observe the following anti-bribery rules:
- (1) All officers and employees of Hankyu Hanshin Holdings Group shall on no account give, offer, or promise any money, privilege, hospitality, objects of value, or any other benefit or advantage to public officials, whether directly or indirectly. As used here, “public officials” includes persons who serve a role analogous to that of a public official. Additionally, officers and employees shall on no account accept any privilege, hospitality, objects of value, or any other benefit or advantage beyond that which can be justified as business practice or within social norms.
- (2) Whenever officers or employees of Hankyu Hanshin Holdings Group pay money to public officials, they shall accurately record the payment and properly manage the record.
Organizational Support for Combatting Corrupt Practices
Hankyu Hanshin Holdings Group shall provide training to ensure that its officers and employees fully understand this policy. Member organizations of the Hankyu Hanshin Holdings Group shall provide anti-corruption guidelines that are relevant to their business profile.
Organizational Response to Corrupt Practices
Hankyu Hanshin Holdings Group shall provide information about, and facilitate the use of, the Corporate Ethics Consultation Desk, a means by which any of the Group’s officers or employees, or any trading partners or other interested parties, can swiftly report any violations or suspected violations. The Group shall address any reports swiftly and effectively.
Effective March 1, 2022
Hankyu Hanshin Holdings Inc.
3. Raising Awareness Among All Officers and Employees
We seek to raise awareness among all Group officers and employees regarding compliance issues through a variety of training activities and communication as described below.
- New recruit training, training upon promotion
- Training upon first appointment to director or auditor position at a Group affiliate
- Collective training for Group companies' compliance officers
- On-site training at Group companies
- Compliance-related serials in Group magazines
- Compliance-related e-mail newsletter featuring case studies and updates regarding laws and regulations
- Compliance-related information posted on the Group intranet
4. Groupwide Internal Control through Internal Audits
The Group Auditing Division conducts internal audits of the Company in collaboration with the accounting auditors and others in an effort to enhance Groupwide internal control.