COMPLIANCE
Compliance
Ethical Code for Officers and EmployeesCODE OF ETHICS
Code of Conduct: Message for officers and employees
We have established the “Four Missions Statement,” which is our corporate philosophy, as well as company rules to promote legal and
fair business activities. With the increasing importance of fair corporate activities and corporate ethics not to mention legal and
regulatory compliance, we have compiled matters that each officer and employee should especially keep in mind as the “HOKKAN
HOLDINGS Code of Conduct for Officers and Employees” to ensure overall compliance by the company.
HOLDINGS Code of Conduct for Officers and Employees” to ensure overall compliance by the company.
Officers and employees shall utilize this Code of Conduct as a
guide for daily behavior, to raise awareness of their
responsibilities as a member of the company, reconfirm
applicable laws, systems and company rules related to their
duties, and further promote responsible behavior.
guide for daily behavior, to raise awareness of their
responsibilities as a member of the company, reconfirm
applicable laws, systems and company rules related to their
duties, and further promote responsible behavior.
Should any compliance issues arise, employees must
immediately report to their boss and relevant stakeholders to
take appropriate measures. Management level employees should
maintain daily communication with their subordinates to create
an atmosphere where employees can consult their boss
whenever a problem arises, in an effort to prevent problems
from arising or aggravating and to facilitate timely and
appropriate response.
immediately report to their boss and relevant stakeholders to
take appropriate measures. Management level employees should
maintain daily communication with their subordinates to create
an atmosphere where employees can consult their boss
whenever a problem arises, in an effort to prevent problems
from arising or aggravating and to facilitate timely and
appropriate response.
Code of Conduct for Officers and EmployeesCODE OF CONDUCT
Basic Philosophy
All officers and employees of the Hokkan Holdings Group must be ready to continue to accept new challenges untiringly for growth with a pioneering spirit. They should be deeply conscious of the need for their activities to be sustainable and in harmony with the environment and society, in order to achieve continued growth within the Group’s various fields of business and to enhance corporate value in the medium and long term. In addition to adhering strictly to all laws, regulations, and company rules, all officers and employees must conduct themselves responsibly at all times in line with good professional etiquette and social norms.
Rules
Respect human rights and have no
involvement in any discrimination or
harassment.
Adhere strictly to environmental treaties,
laws, and regulations, and take the
natural environment into consideration in all your
professional activities.
In your business dealings, adhere strictly to
all laws and regulations, and make it a
principle to act fairly at all times.
As well as safeguarding Group information
appropriately, exercise due care with the
proper management of information obtained
from outside the company and the handling
of third-party intellectual property rights.
Do not engage in unfair trading in stocks and
shares (insider trading).
Do not carry out any actions that go against
the interests of any Group company. Maintain
a strict division between public and private
affairs.
involvement in any discrimination or
harassment.
laws, and regulations, and take the
natural environment into consideration in all your
professional activities.
all laws and regulations, and make it a
principle to act fairly at all times.
appropriately, exercise due care with the
proper management of information obtained
from outside the company and the handling
of third-party intellectual property rights.
shares (insider trading).
the interests of any Group company. Maintain
a strict division between public and private
affairs.
Gifts, hospitality, and other forms of
entertainment must never infringe laws or
other regulations, and should be kept to
appropriate limits in line with social
conventions.
Take a firm stand against antisocial elements
and do not contribute to their interests in
any way.
In pursuing your business, take responsibility
for the quality and safety of our products at
all times.
Take care of your own health and safety and
ensure that you do not harm the health and
safety of others.
Do not neglect or turn a blind eye to
inappropriate acts or a situation requiring
attention. Each individual has a responsibility
to act.
entertainment must never infringe laws or
other regulations, and should be kept to
appropriate limits in line with social
conventions.
and do not contribute to their interests in
any way.
for the quality and safety of our products at
all times.
ensure that you do not harm the health and
safety of others.
inappropriate acts or a situation requiring
attention. Each individual has a responsibility
to act.
Supplementary Provisions
This code of conduct applies to all officers and employees of the Hokkan Holdings Group
(including advisors, non-regular staff, and assigned employees), and to those working at any
Group company as dispatched workers.
(including advisors, non-regular staff, and assigned employees), and to those working at any
Group company as dispatched workers.
Detailed provisions are appended to this code of conduct.
As with other company rules, disciplinary measures to be taken in response to infringements
of this code of conduct will be decided according to the rules of employment, in line with the
nature and seriousness of the infringements.
of this code of conduct will be decided according to the rules of employment, in line with the
nature and seriousness of the infringements.
The Compliance Committee (under the control of the Department of General Affairs) will be
responsible for operating the Code of Conduct. Any significant changes require the approval
of the Board of Directors.
responsible for operating the Code of Conduct. Any significant changes require the approval
of the Board of Directors.
Code of Conduct for Officers and EmployeesCODE OF CONDUCT
Respect human rights and have no involvement in any discrimination or harassment.
No discrimination will be tolerated for any reason, including on grounds of race, skin color, faith, religion, gender, sexual
orientation, gender identity, nationality, age, place of origin, physical or mental disability, or illness.
orientation, gender identity, nationality, age, place of origin, physical or mental disability, or illness.
Do not carry out any act detrimental to the physical or mental wellbeing or dignity of another person, including sexual
harassment, power harassment, or any other type of harassment.
harassment, power harassment, or any other type of harassment.
Work to have a correct understanding and awareness of human rights issues, including issues involving discrimination
against persons from certain communities, and do not discriminate on any grounds.
against persons from certain communities, and do not discriminate on any grounds.
The Compliance Committee (with the Department of General Affairs serving as secretariat) will be responsible for operating
the Code of Conduct. Any significant changes require the approval of the Board of Directors
the Code of Conduct. Any significant changes require the approval of the Board of Directors
Employees must respect the cultures, customs, and languages of different countries and regions and should strive to blend in
harmoniously with the international community and local communities.
harmoniously with the international community and local communities.
Adhere strictly to environmental treaties, laws, and regulations, and take the
natural environment into consideration in all your professional activities.
Adhere to all environmental treaties, laws, and regulations, and work to contribute to environmental protection.
The impact on the environment and ecosystems should be taken into consideration in all business activities.
Use resources and energy efficiently, reduce waste, and strive for efficient reuse and recycling.
As well as understanding and working to achieve the environmental targets of the Group, officers and employees should take
a lead on environmental activities in their local communities.
a lead on environmental activities in their local communities.
In your business dealings, adhere strictly to all laws and regulations, and make it a
principle to act fairly at all times.
Adhere strictly to all business laws relating to products and services, and ensure that there are no omissions or oversights
with regard to obtaining permissions, submissions of required forms, and other procedures.
with regard to obtaining permissions, submissions of required forms, and other procedures.
Do not engage in any unfair restraint of trade by carrying out consultations and agreements with other companies in the
same industry and within an industry group regarding price, production volume, facilities, and market allocations.
same industry and within an industry group regarding price, production volume, facilities, and market allocations.
Do not collude with other companies in the same industry or within an industry group to refuse or terminate business
dealings with a particular business operator (including discount dealers) or new entrants to the market. No collusive
bidding or bid rigging will be tolerated.
dealings with a particular business operator (including discount dealers) or new entrants to the market. No collusive
bidding or bid rigging will be tolerated.
As a general rule, there should be no contact with competitor companies. Where such contact is unavoidable, procedures
should be taken in advance in accordance with the company rules.
should be taken in advance in accordance with the company rules.
Do not take any inappropriate action injurious to the interests of subcontractors.
As well as safeguarding Group information appropriately, exercise due care with
the proper management of information obtained from outside the company and the
handling of third-party intellectual property rights.
the proper management of information obtained from outside the company and the
handling of third-party intellectual property rights.
Strictly manage the confidential information of Group companies, prevent leakages, and ensure that this information is not
used except for the intended business purposes.
used except for the intended business purposes.
If it becomes necessary to disclose confidential information of Group companies to a source outside the company for
business reasons, take due care to prevent leakages of this information, such as by signing a non-disclosure agreement in
advance and any other steps that may be necessary.
business reasons, take due care to prevent leakages of this information, such as by signing a non-disclosure agreement in
advance and any other steps that may be necessary.
Even after leaving employment with the company, no employee may allow confidential information of any Group company to
leak, or use such information themselves for any purpose.
leak, or use such information themselves for any purpose.
Any confidential information received from a non-Group third party must be handled with due care to prevent any leakage,
and must not be used except for the intended purpose. Be aware of the duty to maintain confidentiality, and handle all
information appropriately at all times.
and must not be used except for the intended purpose. Be aware of the duty to maintain confidentiality, and handle all
information appropriately at all times.
In responding to questions from outside the company, do not respond based on your personal judgement, but relay the
inquiry to the department designated to handle such inquiries.
inquiry to the department designated to handle such inquiries.
Do not make unauthorized copies of any computer software or engage in other actions that infringe the intellectual property
of third parties.
of third parties.
Do not engage in unfair trading in stocks and shares (insider trading).
If you learn of important information concerning any Group company that is likely to have a significant impact on investment
decisions, you must not buy or sell shares in that Group company before the information is made public.
decisions, you must not buy or sell shares in that Group company before the information is made public.
If you learn of important information concerning any supplier or business partner that is likely to have a significant impact
on investment decisions, you must not buy or sell shares in that company before the information is made public.
on investment decisions, you must not buy or sell shares in that company before the information is made public.
If you learn of important information concerning a group company or business partner that is likely to have a significant
impact on investment decisions, you must not transmit this information to any other party until the facts are made public,
and must not advise anyone to buy or sell shares in that company.
impact on investment decisions, you must not transmit this information to any other party until the facts are made public,
and must not advise anyone to buy or sell shares in that company.
If you are considering buying or selling shares in a group company, ensure you take all the necessary steps in advance based
on company rules.
Do not carry out any actions that go against the interests of any group company.
Maintain a strict division between public and private affairs.
Do not make inappropriate use of the tangible or intangible assets of any Group company.
Do not use the property or expenses of any Group company for personal reasons.
Do not use any Group information system inappropriately.
Do not engage in outside work without the permission of the company.
Return all Group company property on termination of employment.
Do not carry out political or religious activities or any other personal activities unrelated to company business while in the
workplace.
Gifts, hospitality, and other forms of entertainment must never infringe laws or
other regulations, and should be kept to appropriate limits in line with social
conventions.
No bribe may be offered, promised, or given, either directly or indirectly, nor may any bribe be demanded or accepted.
No entertainment or other economic benefits shall be given to public officials or persons in an equivalent position, either in
Japan or overseas. Any exception to this rule must be made in line with social mores and within the bounds of accepted
conventions. All necessary approval procedures should be taken in advance, and confirmation obtained after the event.
Japan or overseas. Any exception to this rule must be made in line with social mores and within the bounds of accepted
conventions. All necessary approval procedures should be taken in advance, and confirmation obtained after the event.
If you learn that any part of a Group company’s payment to agents and consultants will be or may be misused in an attempt
to gain inappropriate influence with public officials or persons in an equivalent position, do not proceed with the payment.
to gain inappropriate influence with public officials or persons in an equivalent position, do not proceed with the payment.
Do not give extravagant gifts or lavish entertainment to client companies or their executives. Corporate entertainment
should be carried out within appropriate limits and in line with social conventions.
should be carried out within appropriate limits and in line with social conventions.
Officers and employees must not personally receive rebates, benefits, or other economic advantages from business partners
and client companies in the performance of their duties. Nor shall they accept excessive entertainment or gifts that exceed
the bounds of social propriety. In accordance with company rules, approval must be obtained for all corporate entertainment
received by officers and employees.
and client companies in the performance of their duties. Nor shall they accept excessive entertainment or gifts that exceed
the bounds of social propriety. In accordance with company rules, approval must be obtained for all corporate entertainment
received by officers and employees.
Take a firm stand against antisocial elements and do not contribute to their interests in any way.
If you receive an unreasonable demand from an antisocial (criminal) organization, you should consult your supervisor
immediately and deal with the situation on a company level. Never attempt to deal with such a situation alone, and do not
attempt to find an easy solution with money or similar means.
immediately and deal with the situation on a company level. Never attempt to deal with such a situation alone, and do not
attempt to find an easy solution with money or similar means.
Care should be taken at all times to guard against approaches by antisocial (criminal) organizations, who can be expected to
attempt to gain ground through conventional business approaches.
attempt to gain ground through conventional business approaches.
In pursuing your business, take responsibility for the quality and safety of our
products at all times.
Take steps to maintain and improve quality and ensure product safety at all times. In addition to complying with all laws,
regulations, and company rules, this includes strict adherence to the standards, procedures and work protocols established
within each workplace.
regulations, and company rules, this includes strict adherence to the standards, procedures and work protocols established
within each workplace.
Do not do or cause other people to do anything that is injurious to product quality and safety. Take care at all times to
ensure that situations damaging to quality and safety do not arise as a result of defects or flaws in the workplace. If you
become aware of any such deficiencies, consult your supervisor immediately.
ensure that situations damaging to quality and safety do not arise as a result of defects or flaws in the workplace. If you
become aware of any such deficiencies, consult your supervisor immediately.
Take care of your own health and safety and ensure that you do not harm the
health and safety of others.
health and safety of others.
Remember that your health and safety are the number one priority for the company. Take care of your own health at all
times, and take care not to harm the health and safety of any officer, employee, dispatch worker, contractor, or any other
person.
times, and take care not to harm the health and safety of any officer, employee, dispatch worker, contractor, or any other
person.
In carrying out your professional duties, follow the procedures stipulated by the laws and regulations relating to safety and
hygiene in the workplace and company rules and manuals.
hygiene in the workplace and company rules and manuals.
Play an active part in creating a workplace with an open atmosphere conducive to good communication, and strive to
maintain and promote physical and mental health.
maintain and promote physical and mental health.
If you discover a dangerous situation in the course of your duties, do not ignore it. Inform a manager or supervisor
immediately and take steps to prevent workplace accidents and incidents before they occur.
immediately and take steps to prevent workplace accidents and incidents before they occur.
Do not consume alcohol or smoke in a way that might adversely affect health and safety.
Do not neglect or turn a blind eye to inappropriate acts or a situation requiring
attention. Each individual has a responsibility to act.
If you discover any violation of this code, or are inadvertently responsible for a violation yourself, you must promptly report
this to the internal reporting system and seek advice.
this to the internal reporting system and seek advice.
Officers and employees of all Group companies must cooperate as necessary to enable the company to confirm the facts and
take appropriate action, including measures to prevent recurrence.
take appropriate action, including measures to prevent recurrence.
A member of the internal reporting system who receives a report or request for advice from an employee must not reveal the
name of the employee without that person’s consent, and must ensure that the person does not suffer any disadvantage as a
result of coming forward.
name of the employee without that person’s consent, and must ensure that the person does not suffer any disadvantage as a
result of coming forward.
The Compliance Committee must be notified immediately if any disadvantage results to an employee or other individual for
reporting a violation. The Committee will investigate and confirm the facts and take immediate action as necessary.
reporting a violation. The Committee will investigate and confirm the facts and take immediate action as necessary.
Reports of any possible infringements of this code should be carried out in line with the procedures indicated on the hotline
information card.
information card.