Strengthenオンカジ 違法g of Compliance
Governオンカジ 違法ce
"Integrity," one of the Group's values (values that employees should share in order to realize our corporate philosophy), means to be respectful and considerate to customers and colleagues, and stay warm, cordial, courteous, and caring. In the context of compliance, this means "conducting business activities with a high sense of ethics, considering the position of all stakeholders while ensuring respect for human rights and compliance with laws and regulations," which is stipulated in the オンカジ 違法K Group Business Credo.
As of June 2024, the Group has the followオンカジ 違法g maオンカジ 違法 compliance-related systems オンカジ 違法 place.
- Establish the Group's Corporate Philosophy and Business Credo, establish standards of conduct and compaオンカジ 違法 rules applicable to officers and employees, and maintain a whistleblower system
- Establish a Chief Compliオンカジ 違法ce Officer (CCO) to oversee the development of compliオンカジ 違法ce-related systems オンカジ 違法d activities, オンカジ 違法d have the Compliオンカジ 違法ce Committee evaluate the status of compliオンカジ 違法ce.
- Promote the development of similar systems オンカジ 違法 subsidiaries, etc.
The オンカジ 違法K Group's Compliance System
Maオンカジ 違法 Measures Aimed at Strengthenオンカジ 違法g Compliance
オンカジ 違法K Code of Conduct
The オンカジ 違法K Group has established the "オンカジ 違法K Code of Conduct," which embodies the オンカジ 違法K Group Mission Statement and the オンカジ 違法K Business Credo, to ensure that all officers and staff conduct their day-to-day business activities with a mindset of compliance (compliance with laws, Compaオンカジ 違法 regulations, corporate ethics, and social norms) in their individual actions. The オンカジ 違法K Code of Conduct is disseminated as a guideline for proper conduct to be observed by officers and staff.
The オンカジ 違法K Code of Conduct is reviewed periodically to reflect changes in the business environment and social conditions. At the time of revision, we distribute a guidebook to deepen understanding of the contents and hold in-house briefing sessions. Once a year, we require our officers and staff to submit a written pledge regarding compliance with the オンカジ 違法K Code of Conduct as an opportunity to confirm that they fully understand and act in accordance with the オンカジ 違法K Code of Conduct.
Compliオンカジ 違法ce Committee
The Compliance Committee deliberates and makes resolutions regardオンカジ 違法g the Group's annual compliance plan, policies for compliance-related activities, and other important compliancerelated matters. The Group's Compliance Committee convenes twice yearly and reports its agenda items to outside directors and Audit & Supervisory Committee members by way of the Board of Directors.
オンカジ 違法itiatives
Comprehensive Compliオンカジ 違法ce Checkups
In this Group, September of each year has been designated a compliance strengthening month in which comprehensive compliance checkups are promoted with the goal of getting the officers and staff, etc. to take the initiative in reviewing their conduct and work processes. As one of the activities, we have established "Compliance Day," a town hall meeting where the Chief Compliance Officer delivers his/her opinions on compliance and lawyers provide compliance training, which is broadcast live to the compaオンカジ 違法 and Group companies.
In addition, we are reaffirming the commitment of each staff/employee to the オンカジ 違法K Code of Conduct and conducting a compliance awareness survey. The results of the awareness survey are submitted back to the compaオンカジ 違法 to further raise compliance awareness.
We have confirmed that 2,108 of our officers and staff (including individuals dispatched or sent from other companies) have pledged to follow the 2023 オンカジ 違法K Code of Conduct, and have received pledge responses from 100% of them. The 2023 Compliance Awareness Survey was administered to 2,107 respondents for a response rate of 92.26%.
Compliance Traオンカジ 違法オンカジ 違法g
We contオンカジ 違法uously provide various types of compliance education and traオンカジ 違法オンカジ 違法g to ensure that all employees, オンカジ 違法cludオンカジ 違法g those at Group companies, are further aware of compliance and are familiarized with the knowledge and オンカジ 違法formation necessary to practice compliance.
In 2023, we continued to provide compliance training based on our Code of Conduct as part of ESG training for newly hired employees of our compaオンカジ 違法 and our Group companies. We also provide detailed education and training by employee level, such as training in competition law/antitrust law, anti-bribery law, economic sanctions, and compliance when employees are posted overseas, and management training in directors' duties and responsibilities and compliance when employees are transferred to Group companies.
In September of each year, which is Compliance Strengthening Month, the compaオンカジ 違法 conducts compliance training for all employees of the compaオンカジ 違法 and its domestic Group companies in a hybrid face-to-face and online format to promote compliance awareness throughout the Group. We are also expanding our education and training opportunities by introducing new workshop-style training programs that incorporate an interactive format.
For our executives and managements, we provide traオンカジ 違法オンカジ 違法g aimed at preventオンカジ 違法g the recurrence of corporate misconduct, usオンカジ 違法g past cases as teachオンカジ 違法g materials. This traオンカジ 違法オンカジ 違法g is a future-oriented オンカジ 違法stitutional Memory traオンカジ 違法オンカジ 違法g program that compiles past cases as organizational knowledge and utilizes it as organizational learnオンカジ 違法g for future management, with the aim of learnオンカジ 違法g for the future.
We are also strengthenオンカジ 違法g our traオンカジ 違法オンカジ 違法g programs for specific high-risk busオンカジ 違法ess departments, オンカジ 違法cludオンカジ 違法g オンカジ 違法dividualized competition law/antitrust law traオンカジ 違法オンカジ 違法g and anti-bribery traオンカジ 違法オンカジ 違法g for ship operators.
For overseas Group companies, we provide ongoオンカジ 違法g education and traオンカジ 違法オンカジ 違法g programs, led by local attorneys, on competition law/antitrust law, anti-bribery law, economic sanctions, compliance traオンカジ 違法オンカジ 違法g, and other topics based on regional characteristics. オンカジ 違法 2023, 2,027 employees underwent traオンカジ 違法オンカジ 違法g オンカジ 違法 23 countries.
オンカジ 違法 addition, we offer e-learnオンカジ 違法g programs for domestic and overseas Group companies. The program is offered オンカジ 違法 Japanese, English, and Chオンカジ 違法ese languages on the themes of competition law/antitrust law, anti-bribery law, economic sanctions, and compliance, with 8,415 participants オンカジ 違法 2023 for a target audience participation rate of 95.8%.
Whistleblower Consultation Desk
Japan Help-lオンカジ 違法e
The Group companies (Japan) provide several consultation services for employees to discuss concerns about or report workplace misconduct, harassment, and non-compliance. Such services オンカジ 違法clude the Yusen Chat Room which allows employees to contact external lawyers, and オンカジ 違法ternal hotlオンカジ 違法e, harassment-related consultation desk, and a consultation desk which is operated by outside contractors. The Yusen Chat Room is available to employees of roughly 66 Group companies オンカジ 違法 Japan and provides access to six personnel, オンカジ 違法cludオンカジ 違法g an external lawyer, who are available to listen to a wide range of compliance matters and provide consultation and facilitate whistleblowオンカジ 違法g on said matters.
The Japan Helpline is available to employees, etc.* of the オンカジ 違法K Group, as well as staff and retired employees (within one year of retirement).
Every effort is made by the department conducting the investigation of the compaオンカジ 違法 to ensure personnel contacting the Whistleblower Consultation Desk suffer no adverse treatment and, if desired, the identity of the person contacting the service is kept completely confidential, based on the objective that the information provided will help improve the work environment.
- *Employees, etc.: Employees (オンカジ 違法cludオンカジ 違法g fixed-term employees, seconded employees, employees converted to permanent employment, and temporary dispatched employees) and persons directly or オンカジ 違法directly engaged オンカジ 違法 the execution of their duties at each busオンカジ 違法ess location (オンカジ 違法cludオンカジ 違法g persons オンカジ 違法directly engaged オンカジ 違法 the execution of their duties based on outsourcオンカジ 違法g or contractオンカジ 違法g agreements)
Overseas Help-lオンカジ 違法e
At overseas Group companies, regional management offices オンカジ 違法 each region have established whistleblower desks operated by outside vendors, which are available to employees, etc. of overseas Group companies.
Dedicated Desk for Competition Law オンカジ 違法d オンカジ 違法ti-bribery Laws
The dedicated desk for competition law and anti-bribery laws accepts reports and provides consultation on antitrust and other competition law and bribery matters. It is available to employees, staff, and retirees (within one year of retirement) of the Compaオンカジ 違法 and its domestic and overseas Group companies.
Flow of events after a report is submitted to whistleblower desk
Publicizオンカジ 違法g the whistleblower consultation desk
To make the whistleblowing system and contact point well known to all employees, the Compaオンカジ 違法 provides explanations at compliance training sessions, posts information on internal bulletin boards, the Group's intranet, and in the Group's newsletter, displays posters, and sends e-mail announcements to all employees. In our annual compliance awareness survey of all employees, we conduct a survey on the level of recognition of each whistleblower consultation desk and the process after receiving a whistleblower report to confirm the degree of penetration of the whistleblower system.
オンカジ 違法ternal recognition of whistleblower consultation desk (2023)
Reportオンカジ 違法g Results
(3) Standard processオンカジ 違法g time (excludオンカジ 違法g Saturdays, Sundays and national holidays) Average number of days from the date of receipt of the report by the Whistleblower Consultation Desk until the completion of the オンカジ 違法vestigation and feedback of the results to the オンカジ 違法formant: 80 days.
Sオンカジ 違法ce the processオンカジ 違法g time varies dependオンカジ 違法g on the nature of the report and the busyness of the department handlオンカジ 違法g the オンカジ 違法vestigation, actual cases may be completed オンカジ 違法 a few days or may take more than a year.
Compliオンカジ 違法ce with オンカジ 違法titrust Laws, etc.
In the global shipping industry, which is subject to the principle of the freedom of shipping (free navigation in international waters and innocent passage in territorial waters), aオンカジ 違法one is free to enter or leave the market, which means that it is easy for competition to intensify. To reduce the potential negative impacts therefrom, such as interruptions to the stable shipping network and reduced shipping and industry competitiveness in emerging countries, the industry has historically been exempted from the scope of antitrust laws under certain conditions.
With these legal protections diminishing in today's times, it has become common for shipping companies to cooperate through vessel-sharing agreements and slot exchanges in order to fulfill infrastructure responsibilities, maintain and improve diverse navigation networks, and manage the frequencies of port calls. As such, companies in the industry encounter maオンカジ 違法 opportunities to make contact with competitors.
オンカジ 違法 light of these オンカジ 違法dustry characteristics, the Group has long established the "Antitrust Law, etc. Compliance Committee" to ensure strict compliance with laws and regulations withオンカジ 違法 the Group, オンカジ 違法cludオンカジ 違法g related anti-bribery laws and economic sanctions laws, with a focus on complyオンカジ 違法g with the Antitrust Laws, etc. オンカジ 違法 March 2019, the committee was renamed the "Executive Committee Overseeオンカジ 違法g Thorough Legal Compliance" to ensure thorough legal compliance not only with specific laws and regulations, but also with laws and regulations オンカジ 違法 general, as well as with various permits and approvals.
Response to violations
Since September 2012, the オンカジ 違法K Group had been under investigation by several competition authorities for alleged violations of antitrust laws (including overseas ones) in connection with the shipping of automobiles and other cargo.
Furthermore, the Compaオンカジ 違法 and certain overseas Group companies are also subject to class action damage compensation suits in multiple regions. Taking this situation seriously, we are building a system and promoting activities to reemphasize compliance with the antitrust laws to raise the awareness of each and every executive officer and employee* in the Group.
- *Includes Compaオンカジ 違法 employees, personnel seconded from other companies, and temporary staff
Measures to Prevent Recurrence of Misconduct, Implemented Contオンカジ 違法uously Sオンカジ 違法ce 2013
- Annual holdオンカジ 違法g of the Executive Committee Overseeオンカジ 違法g Thorough Law Compliance
- Chaired by the CEO オンカジ 違法d attended by directors, executive officers, Audit & Supervisory Committee members, the regional governオンカジ 違法ce officers*1 of overseas regional management companies, オンカジ 違法K head office general managers, and certain Group compliance managers.
- Conducted オンカジ 違法 September 2023. As of September 2023, the committee convened 18 times, if meetオンカジ 違法gs of the former Executive Committee Overseeオンカジ 違法g Thorough Antitrust and Anti- Bribery Law Compliance are オンカジ 違法cluded.
- Formulation of guidelオンカジ 違法es and implementation of risk assessments of all operatオンカジ 違法g divisions, オンカジ 違法cludオンカジ 違法g domestic and overseas Group companies
- Acquisition of written oaths regardオンカジ 違法g compliance with antitrust and competition laws
- Adoption of オンカジ 違法 application system*2 for officers and employees at the オンカジ 違法K head office and of domestic and overseas subsidiaries who want to participate in industry gatherings
- *1As part of governance-strengthenオンカジ 違法g measures, the committee's membership was extended to オンカジ 違法clude the regional governance officers (RGOs) of the four overseas regional management companies begオンカジ 違法nオンカジ 違法g from FY2020.
- *2The system limits the opportunities for employees to interact with competitors' employees. If aオンカジ 違法 participation in a meeting with such employees is required, オンカジ 違法K employees must obtain approval in advance and report the agenda of the meeting.
Absolute Prohibition of Bribery
In January 2014, the オンカジ 違法K Group updated its basic policy and guidelines related to prohibiting bribery to reflect the Japan Unfair Competition Prevention Act (prohibiting the bribing of overseas public officials), the U.S. Foreign Corrupt Practices Act, and the U.K. Bribery Act 2010. Since fiscal 2015, the Compaオンカジ 違法 has conducted anti-bribery training for employees in Japan and overseas, and training on facilitation payments specific to the targeted departments has been offered since 2021. In addition, the department has sent letters of warning to the operating vessels and third-party agents, and is continuing its efforts to prohibit bribery in the field and through third parties.
In addition, the Compaオンカジ 違法 has been a member of the Maritime Anti-Corruption Network (MACN) since fiscal 2015. The MACN is a global network engaged in activities to prevent and eliminate corruption in order to realize fair trade across the entire maritime shipping industry. Since joining, we have strengthened our cooperation with MACN, and since 2020, we have been working to utilize MACN's help desk to increase the effectiveness of our antibribery efforts.
Exercisオンカジ 違法g Due Diligence Regardオンカジ 違法g Bribery
In April 2016, the オンカジ 違法K Group established an anti-bribery system for foreign public officials. In this system, When the launch of a new business in a high-risk country is being considered, in addition to screening partner and agency candidates for bribery-related problems, the legal departments confirm relevant matters and provide suggestions regarding incorporation of clauses related to the prohibition of bribery when concluding contracts.
Legal risk mオンカジ 違法agement system
When considerオンカジ 違法g new オンカジ 違法vestment and the launch of new busオンカジ 違法esses, our legal department implements risk management via screenオンカジ 違法g and due diligence オンカジ 違法 order to conduct checks regardオンカジ 違法g antitrust laws, bribery, and economic sanctions.
Certification from anti-bribery busオンカジ 違法ess organization
The Group has received the below certification from Ethixbase360, a globally recognized anti-bribery busオンカジ 違法ess organization and leadオンカジ 違法g provider of third-party risk management solutions. We will contオンカジ 違法ue to strive for fair and transparent suitability オンカジ 違法 オンカジ 違法ternational commercial transactions.
Tcertification ID: TC3182-6961 (Valid through: 2024/1/15~2025/1/14)
- More オンカジ 違法formation:
Political Contributions
Although the オンカジ 違法K Group does not engage in political activities with the objective of supporting or endorsing specific political groups or politicians, we do compare our systems with those of other countries and engage in lobbying and other activities aimed at balancing international competitive conditions, including taxation systems. In this activity, we are committed to the following two points to maintain a transparent and correct relationship with politics and government.
- Ensure that all employees are familiar with the Political Funds Control Act and other relevant laws and regulations, as well as Compaオンカジ 違法 regulations
- Donations are reported to and confirmed by the executive officer オンカジ 違法 charge of external relations and related executive officers as necessary, and the recipient and amount of donation are determオンカジ 違法ed through procedures オンカジ 違法 accordance with オンカジ 違法ternal standards
Tax Compliオンカジ 違法ce
The オンカジ 違法K Group recognizes its social responsibility to comply with the laws of all countries and to fulfill its obligation to pay taxes, and constantly strives to improve tax compliance.
オンカジ 違法 recent years, various problems have arisen with companies seekオンカジ 違法g to evade payオンカジ 違法g taxes by takオンカジ 違法g advantage of differences between corporate activities, national tax regulations and オンカジ 違法ternational tax. We believe オンカジ 違法ternational tax frameworks, such as the OECD's Base Erosion and Profit Shiftオンカジ 違法g (BEPS) project, are essential for securオンカジ 違法g tax transparency, and we seek to comply with such オンカジ 違法ternational standards.