オンカジ 違法
Governance
"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 Business Credo.
As of June 2024, オンカジ 違法 the following main compliance-related systems in place.
- Establish オンカジ 違法 Corporate Philosophy and Business Credo, establish standards of conduct and company rules applicable to officers and employees, and maintain a whistleblower system
- Establish a Chief Compliance Officer (CCO) to oversee the development of compliance-related systems オンカジ 違法ctivities, and have the Compliance Committee evaluate the status of compliance.
- Promote the development of similar systems in subsidiaries, etc.
The オンカジ 違法's Compliance System
Main Measures Aimed at Strengthening Compliance
NYK オンカジ 違法
The オンカジ 違法 has established the "NYK Code of Conduct," which embodies the オンカジ 違法 Mission Statement and the NYK Business Credo, to ensure that all officers and staff conduct their day-to-day business activities with a mindset of compliance (compliance with laws, Company regulations, corporate ethics, and social norms) in their individual actions. The NYK Code of Conduct is disseminated as a guideline for proper conduct to be observed by officers and staff.
The NYK オンカジ 違法 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 NYK オンカジ 違法 as an opportunity to confirm that they fully understand and act in accordance with the NYK オンカジ 違法.
オンカジ 違法
The Compliance Committee deliberates and makes resolutions regarding 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 オンカジ 違法 Board of Directors.
Initiatives
オンカジ 違法
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 オンカジ 違法 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 company and Group companies.
In addition, we are reaffirming the commitment of each staff/employee to the NYK オンカジ 違法 and conducting a compliance awareness survey. The results of the awareness survey are submitted back to the company 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 NYK オンカジ 違法, 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%.
オンカジ 違法
We continuously provide various types of compliance education and training to ensure that all employees, including those at Group companies, are further aware of compliance オンカジ 違法re familiarized with the knowledge and information necessary to practice compliance.
In 2023, we continued to provide compliance training based on our オンカジ 違法 as part of ESG training for newly hired employees of our company 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 company conducts compliance training for all employees オンカジ 違法 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 training aimed at preventing the recurrence of corporate misconduct, using past cases as teaching materials. This training is a future-oriented Institutional Memory training program that compiles past cases as organizational knowledge and utilizes it as organizational learning for future management, オンカジ 違法 aim of learning for the future.
We are also strengthening our training programs for specific high-risk business departments, including individualized competition law/antitrust law training オンカジ 違法nti-bribery training for ship operators.
For overseas Group companies, we provide ongoing education and training programs, led by local attorneys, on competition law/オンカジ 違法, anti-bribery law, economic sanctions, compliance training, and other topics based on regional characteristics. In 2023, 2,027 employees underwent training in 23 countries.
In addition, we offer e-learning programs for domestic and overseas Group companies. The program is offered in Japanese, English, and Chinese languages on the themes of competition law/オンカジ 違法, anti-bribery law, economic sanctions, and compliance, with 8,415 participants in 2023 for a target audience participation rate of 95.8%.
オンカジ 違法
Japan Help-line
The Group companies (Japan) provide several consultation services for employees to discuss concerns about or report workplace misconduct, harassment, and non-compliance. Such services include the Yusen Chat Room which allows employees to contact external lawyers, and internal hotline, harassment-related consultation desk, オンカジ 違法 consultation desk which is operated by outside contractors. The Yusen Chat Room is available to employees of roughly 66 Group companies in Japan and provides access to six personnel, including an external lawyer, who are available to listen to a wide range of compliance matters and provide consultation and facilitate whistleblowing on said matters.
The Japan Helpline is available to employees, etc.* of the オンカジ 違法, as well as staff and retired employees (within one year of retirement).
Every effort is made by the department conducting the investigation オンカジ 違法 company to ensure personnel contacting the Whistleblower Consultation Desk suffer no adverse treatment and, if desired, the identity オンカジ 違法 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 (including fixed-term employees, seconded employees, employees converted to permanent employment, and temporary dispatched employees) and persons directly or indirectly engaged in the execution オンカジ 違法ir duties at each business location (including persons indirectly engaged in the execution オンカジ 違法ir duties based on outsourcing or contracting agreements)
Overseas Help-line
At overseas Group companies, オンカジ 違法 offices in 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nti-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) オンカジ 違法 and overseas Group companies.
Flow of events after a report is submitted to whistleblower desk
Publicizing the オンカジ 違法
To make the whistleblowing system and contact point well known to all employees, the Company 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 オンカジ 違法 whistleblower system.
Internal recognition of オンカジ 違法 (2023)
Reporting Results
(3) Standard processing time (excluding Saturdays, Sundays and national holidays) Average number of days from the date of receipt オンカジ 違法 report by the Whistleblower Consultation Desk until the completion オンカジ 違法 investigation and feedback オンカジ 違法 results to the informant: 80 days.
Since the processing time varies depending on the nature オンカジ 違法 report and the busyness オンカジ 違法 department handling the investigation, actual cases may be completed in a few days or may take more than a year.
Compliance with オンカジ 違法s, etc.
In the global shipping industry, which is subject to the principle オンカジ 違法 freedom of shipping (free navigation in international waters and innocent passage in territorial waters), anyone 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 オンカジ 違法 industry encounter many opportunities to make contact with competitors.
In light オンカジ 違法se industry characteristics, the Group has long established the "Antitrust Law, etc. Compliance Committee" to ensure strict compliance with laws and regulations within the Group, including related anti-bribery laws and economic sanctions laws, with a focus on complying with the Antitrust Laws, etc. In March 2019, the committee was renamed the "Executive Committee Overseeing Thorough Legal Compliance" to ensure thorough legal compliance not only with specific laws and regulations, but also with laws and regulations in general, as well as with various permits and approvals.
Response to violations
Since September 2012, the オンカジ 違法 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 Company 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 オンカジ 違法s to raise the awareness of each and every executive officer and employee* in the Group.
- *Includes Company employees, personnel seconded from other companies, オンカジ 違法 staff
Measures to Prevent Recurrence of Misconduct, Implemented Continuously Since 2013
- Annual holding オンカジ 違法 Executive Committee Overseeing Thorough Law Compliance
- Chaired by the CEO オンカジ 違法ttended by directors, executive officers, Audit & Supervisory Committee members, the regional governance officers*1of overseas オンカジ 違法 companies, NYK head office general managers, and certain Group compliance managers.
- Conducted in September 2023. As of September 2023, the committee convened 18 times, if meetings オンカジ 違法 former Executive Committee Overseeing Thorough Antitrust and Anti- Bribery Law Compliance are included.
- Formulation of guidelines and implementation of risk assessments of all operating divisions, including domestic and overseas Group companies
- Acquisition of written oaths regarding オンカジ 違法 antitrust and competition laws
- Adoption of an application system*2for officers and employees at オンカジ 違法 head office and of domestic and overseas subsidiaries who want to participate in industry gatherings
- *1As part of governance-strengthening measures, the committee's membership was extended to include the regional governance officers (RGOs) オンカジ 違法 four overseas regional management companies beginning from FY2020.
- *2The system limits the opportunities for employees to interact with competitors' employees. If any participation in a meeting with such employees is required, NYK employees must obtain approval in advance and report the agenda オンカジ 違法 meeting.
Absolute Prohibition of Bribery
In January 2014, the オンカジ 違法 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 Company 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 Company has been a member オンカジ 違法 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.
Exercising Due Diligence Regarding Bribery
In April 2016, the オンカジ 違法 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 オンカジ 違法 system
When considering new investment and the launch of new businesses, our legal department implements risk management via screening and due diligence in order to conduct checks regarding オンカジ 違法s, bribery, and economic sanctions.
オンカジ 違法 anti-bribery business organization
オンカジ 違法 received the below certification from Ethixbase360, a globally recognized anti-bribery business organization and leading provider of third-party risk management solutions. We will continue to strive for fair and transparent suitability in international commercial transactions.
Tcertification ID: TC3182-6961 (Valid through: 2024/1/15~2025/1/14)
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オンカジ 違法
Although the オンカジ 違法 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 オンカジ 違法 Political Funds Control Act and other relevant laws and regulations, as well as Company regulations
- Donations are reported to and confirmed by the executive officer in charge of external relations and related executive officers as necessary, and the recipient オンカジ 違法mount of donation are determined through procedures in accordance with internal standards
オンカジ 違法
The オンカジ 違法 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.
In recent years, various problems have arisen with companies seeking to evade paying taxes by taking advantage of differences between corporate activities, national tax regulations オンカジ 違法ternational tax. We believe international tax frameworks, such as the OECD's Base Erosion and Profit Shifting (BEPS) project, are essential for securing tax transparency, and we seek to comply with such international standards.