Compliance

ITO EN established the Compliance Committee and the Compliance Department on May 1, 2004 and stipulated “legal compliance" as our basic management policy, and declared our intention to aim for “the ITO EN Group: a model of corporate compliance."

The ITO EN Group thoroughly adheres to laws and regulations, basic principles, company regulations, social norms, and corporate ethics, and engages in fair and sincere business activities. It also attaches importance to consumer viewpoints and standpoints when conducting business activities.

To put this into practice, the Group is working to instill the "ITO EN Group Code of Conduct" which embodies the management principle of Always Putting the Customer First, recognizing that its enforcement is fundamental to compliance.

The ITO EN Group Code of Conduct, in conjunction with various policies and declarations based on Always Putting the Customer First, presents the company's approach (basic policy) for the ITO EN Group to properly conduct its business activities and how all people working there should act (code of conduct).

In addition, the ITO EN Group has established Behavior Checkpoints based on "five perspectives" embodying the Company Credo for all employees to bear in mind as they go about their day-to-day activities and the Group also ensures that all employees know about these checkpoints through the provision of regular training.

To ensure compliance, ITO EN has appointed a corporate officer responsible for corporate ethics, who takes responsibility for the compliance management of the overall company. We stipulated “legal compliance” as our basic management policy, and declared our intention to aim for “the ITO EN Group: a model of corporate compliance.”

In 2004, we established the Compliance Committee and Compliance Office, which are advisory bodies to the Board of Directors, thereby establishing a system to promptly consider and implement countermeasures in the event of a serious compliance-related incident. In FY2021, the Compliance Committee met Six times.

In addition, we have appointed "compliance promotion officers" at each business unit and business base as well as "compliance leaders" for sales headquarters and sales areas across Japan. Through collaboration across our operations, we consider in detail how to prevent the occurrence or reoccurrence of compliance violations and strive to strengthen compliance.

As a framework for liaising, sharing information and exchanging opinions about compliance within the Group, the ITO EN Group has appointed compliance promotion officers at domestic and overseas group companies and holds Group Company Compliance Liaison Committee meetings on a regular basis.

The ITO EN Group has set up a “Corporate Ethics Hotline" that can be used by anyone, including customers, as a contact point for whistleblowing. The hotline accepts reports, consultations and questions from both inside and outside the company for the early detection of various cases, including the prevention of all kinds of corruption, such as working environment issues, human rights violations, bribery, money laundering, embezzlement, and obstruction of justice. It also accepts consultations to prevent bullying and all forms of harassment—including power harassment, sexual harassment, and harassment related to pregnancy / childbirth, childcare / nursing leave.

Reports may be made by the following methods:

• In person
• Regular mail
• Telephone
• E-mail
• FAX

Individuals using the hotline give their name, in principle; however, anonymous reports are also accepted. (Though it is also widely informed that reporting anonymously may prevent the matter from being fully investigated/acted upon.) Users of the hotline will not receive disadvantageous treatment on account of having made a report or consulted the hotline. In accordance with the Whistleblower Protection Act, information contained in whistleblowing reports is kept secret from everyone outside the hotline dealing with the matter and the approval of the whistleblower is obtained if necessary in order for the matter to be acted upon. Through this, the anonymity of the whistleblower is ensured. Matters understood through whistleblowing reports, etc. are reported to the Compliance Committee and dealt with in collaboration with legal counsel, etc.

The ITO EN Group seeks to instil a groupwide culture of compliance through measures such as the systematic provision of compliance training to all officers and employees, aiming to prevent bribery and raise awareness of compliance generally. In FY2020, we provided training and raised awareness about the basics of compliance, complying with laws and regulations, and preventing problems at work.

Furthermore, in measures to strengthen compliance, we hold a compliance promotion month twice a year, we increase understanding of compliance through measures such as providing e-learning and other training, distributing compliance pocket cards, and putting up awareness-raising posters, and we strive to eliminate fraud and create harassment-free workplaces where employees can work safely with peace of mind.

In addition, we encourage compliance leaders to take compliance proficiency tests and currently more than 70% of our compliance leaders have compliance qualifications.

In the event of a compliance violation, we first endeavor to gain an accurate understanding of the facts and investigate the root cause; the established facts are then taken seriously and dealt with strictly, including implementation of thoroughgoing measures to prevent a recurrence and appropriate disciplinary action against any employee involved in the violation.

When ITO EN conducts a transaction with its officers, major shareholders and others, it submits the matter to the Board of Directors in advance and obtains the board's approval in order to ensure that the transaction is not a competitive transaction or conflict of interest transaction or will not otherwise adversely affect the common interests of the Company and shareholders, excluding cases in which the terms and conditions of the transaction are clearly the same as those for general transactions.

ITO EN does not tolerate any form of corruption or fraud in its dealings with any other party, including bribery, money laundering, embezzlement and the obstruction of justice. We will maintain fair and transparent relationships with politicians and public servants, and comply with anti-bribery and corruption laws, regulations and norms concerning matters such as political contributions and the provision of benefits.