Thorough Legal Compliance

We believe that it is indispensable for our sustained growth that each employee holds a high ethical standard and acts according to the common sense and rules of society. All our officers and employees comply thoroughly with regulations in daily corporate activities, and we are working to build a corporate culture that is open-minded and ethical.

Compliance Structure

To give form to our Corporate Ethics Philosophy and Corporate Ethical Standards formulated based on our company creed and mission statement, we, through many initiatives, are promoting corporate activities that are lawful, fair, and in harmony with common sense.

Initiatives to ensure compliance

Formulation of Policies Regarding Compliance

To ensure compliance, including the prevention of bribery, insider trading, and other corrupt practices, as well as the prevention of harassment, we have formulated Group Philosophy, Group Ethical Standards and Rules of Ethical Business Conduct.

Education of officers and employees

Since 2006, we have formulated a compliance manual as a guideline to be observed by all officers and employees, clearly stipulating the prevention of corrupt practices such as bribery and insider trading, as well as the prevention of harassment. The manual is available to all Group employees worldwide in multiple languages. The manual is revised as necessary in line with changes in society and revisions to laws, and the sixth edition was issued in 2024.
Under the leadership of the corporate divisions, we provide training throughout the year tailored to different employee groups: new graduates, mid-career hires, managers, and officers. We also conduct thematic training programs on credit and legal affairs, compliance, insider trading prevention, the prevention of bribery and corruption, and harassment training targeting all employees including managers. Through these initiatives, we work to improve compliance awareness among all officers and employees.

Consultation Desk

We have established an internal consultation desk where all officers and employees of the Group (including contract employees working at Hanwa Group offices based on contracts) and retirees can freely consult or report on compliance in general, including the prevention of corrupt practices such as bribery and insider trading, as well as the prevention of harassment, anonymously if desired. In addition, we have established an external consultation desk operated by an independent law firm. We have also established a dedicated consultation desk where confidentiality is protected for various types of harassment, which are making headlines in recent times, to ensure swift and appropriate response. In addition, we provide a contact point on our website for information and consultations from business partners and other external stakeholders. In addition to enhancing these consultation channels, we have established “Internal Whistleblowing Rules” to ensure proper handling of consultations and reports on misconduct, and we work to identify and resolve problems at an early stage.

Internal management system

We regularly hold the Compliance Committee, composed of officers and general managers from the corporate division, to raise compliance awareness, investigate and address related cases, formulate preventive measures, and report to the Board of Directors. In 2023, under the supervision of the Board of Directors, to prevent all forms of corruption, including bribery and insider trading, we established the "Anti Bribery Rule" and "Insider Trading Prevention Rules," and defined that we prohibit providing benefits to public officials or others for the purpose of obtaining improper advantage.

Responding to social change

In response to requests from the Japan Fair Trade Commission and the Small and Medium Enterprise Agency for fairer trade between business operators, we formulated “Guidelines for Determining Applicability of the Act on Ensuring Proper Transactions Involving Specified Entrusted Business Operators to Transactions” and have disseminated them throughout the company. We are also raising awareness internally by, for example, surveying whether price pass-through of rising labor and raw material costs is being adequately discussed between our business partners. In this way, we have established a system to respond to the social demands, by responding promptly to any revisions to laws and regulations related to corporate activities or to administrative notifications, and by ensuring that measures are deployed internally and strictly observed.

Response to Compliance Cases

In the Company, in the event that a case regarding violation of laws and regulations or internal rules (including prevention of bribery) is discovered, or it is determined that there is a risk of violation, centering on the Committee Chairperson of the Compliance Committee, the Secretariat (Legal Dept.) and related divisions work in cooperation to conduct internal investigations, determine causes, and formulate and implement preventive measures.
Regarding compliance-related cases, the Committee and the Secretariat (Legal Dept.) manage a series of responses from the receipt of reports to the completion of investigation, corrective measures, and preventive measures, and report to the Audit and Supervisory Committee as necessary. For serious cases, based on the instructions of the Committee Chairperson or consultation with the Audit and Supervisory Committee and external experts, we conduct an investigation ensuring independence and fairness, and take appropriate disciplinary action in light of internal rules.
Regarding officers and employees involved in violations of laws and regulations, etc., we verify the necessity of disciplinary action based on internal rules such as work regulations, and upon consultation with internal and external related divisions and experts as necessary, we take appropriate disciplinary action in accordance with prescribed standards and procedures. In addition, if officers and employees voluntarily report or consult, or cooperate with the investigation, we may consider reduction or exemption of the disciplinary action.
The Company considers the necessity of reporting or disclosure to external parties, and implements appropriate responses as necessary.

In addition, in FY2025, there were no serious compliance violations requiring external disclosure.

Please see below for data related to compliance in our ESG disclosures.