Compliance

Promotion of compliance management

Basic thinking on compliance management

KITZ recognizes compliance management as a fundamental and essential condition of continued corporate growth. This is expressed in the first element of the Action Guide for the realization of KITZ’ Statement of Corporate Mission, which expresses the Group’s management philosophy: “Do it True.”

Compliance management promotion structure

To minimize the social and economic effects of related issues, in the KITZ Group, both KITZ and each Group member company have established a Crisis and Compliance (C&C) Control Committee chaired by the president. It also is building structures to prevent various management risks, such as those associated with legal, regulatory, and compliance violations, and to respond swiftly and appropriately to any crises that may arise.

Initiatives related to promotion of compliance management

As part of its duties, the C&C Control Committee at KITZ and each Group member company deliberates on the following matters related to promotion of compliance, formulates necessary policies, and implements specific measures.

• 1. Formulation of basic policies on development and operation of the compliance promotion program.
• 2. Formulation of basic policies on preparation and maintenance of the Compliance Guidebook.
• 3. Formulation of basic policies on implementing compliance education.
• 4. Responding to any compliance violations that have occurred (including investigation of related facts, investigation of their causes, formulation and implementation of measures to prevent their reoccurrence, and checking on the countermeasures implemented).
• 5. Establishment, amendment, and abolition of rules and regulations necessary for compliance promotion.
• 6. Other necessary matters related to compliance promotion.

Whistleblowing system (compliance helpline)

To promote compliance management, KITZ and each Group member company has established compliance helplines as a contact point for reporting and consultation concerning information about any acts in violation of laws, regulations, or compliance identified by directors, audit and supervisory board members, executive officers and employees.

Directors, audit and supervisory board members, executive officers and employees of KITZ and each Group member company may use their own companies’ compliance helplines, compliance helplines set up by outside law firms, and the compliance helpline of the parent company, KITZ. In this and other ways, we secure a structure that directors, audit and supervisory board members, executive officers and employees can use with peace of mind, by setting up multiple routes for consultation and reporting.

Each compliance helpline is managed and operated by the C&C Control Committee of the Company or the Group member company. Reports and consultations received are investigated swiftly while strictly protecting the confidentiality of the reporting party, and timely and appropriate corrective measures are implemented in response.

Compliance education

KITZ distributes a Groupwide Compliance Guidebook common to the Group that describes the compliance program based on the thinking of Group top management (the Company president) concerning compliance management, the importance of compliance management, the compliance promotion structure, the compliance code of conduct, the whistleblowing system, and other matters related to compliance, translated into the language of each country where the KITZ Group has business bases (Japanese, English, Chinese (Simplified and Traditional), Korean, Thai, German, Spanish and Portuguese), to directors, audit and supervisory board members, executive officers and employees of KITZ and Group member companies around the world to educate and raise awareness concerning compliance and to publicize how to use the contact point for whistleblowing reports (compliance helpline).

We also hold systematic seminars on compliance education annually and individual seminars focusing on the details of the operations of each section when so requested by a section of KITZ or a Group member company. Furthermore, we also strive proactively to foster a culture of compliance, raise awareness, and convey related knowledge through various other means, such as preparing and distributing educational and awareness-raising tools and, recently, deployment of digital content using online tools.

Compliance survey

To check on the permeation of compliance management in KITZ and each Group member company and visualize potential compliance risks, KITZ surveys employees on compliance.

The risks identified through this survey are utilized in such efforts as business process improvements and employee education in accordance with their degrees of importance.

Prevention of bribery and corruption

The KITZ Group has been thoroughly tackling to prevent bribery and corruption, which is one of the highest-priority social issues to realize the sustainable society.

In order to achieve the same, the KITZ Group has endorsed the United Nations Global Compact (UNGC) and has proclaimed that it will “work against corruption in all forms, including extortion and bribery.” The KITZ Group has also established and publicized the “KITZ Group Global Anti-Bribery Policy” that clarifies the basic policy on bribery prevention in the KITZ Group and the rules to be followed by its directors, audit and supervisory board members, officers and employees, and clearly prohibits bribery and corruption in the “KITZ Group Compliance Code of Conduct” as well.

In addition, the KITZ Group is also asking its suppliers to comply with, and respect, its “Supplier Guidelines”, which includes the prevention of bribery and corruption.