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Viewing strict compliance as indispensable for business survival, we have made compliance education one of our highest priorities.

Group Code of Conduct

Based on the Group’s management philosophy and company principles, the Group Code of Conduct was established in June 2014 to set forth standards that all Group executives and employees must abide by if the UACJ Group is to be able to move forward as a corporate group that garners even greater trust by society.

The Group Code of Conduct was created in Japanese and preparation of versions in the official languages of the locales of overseas affiliates is moving forward. English, Chinese, Czech, Indonesian, and Thai versions were issued in fiscal 2014, and Spanish and Vietnamese versions in fiscal 2015. In June 2016, we issued a Brazilian Portuguese version in Japan as part of our plans to distribute foreign-language editions of the Group Code of Conduct for the benefit of diversifying workforces at Group companies here.

The Group Code of Conduct is available online in the various languages in which it has been completed.

Compliance Education

As part of its compliance education endeavors, the UACJ Group has posted the Group Code of Conduct on the intranet and distributes abridged editions that all executives and rank-and-file employees can keep with them at all times. In fiscal 2015, department-level seminars on the Group Code of Conduct were held for all employees of UACJ and Group companies in Japan. Afterward, all department heads were asked to pledge to the president of their company that they would uphold the Group Code of Conduct.

Instruction on compliance in general is provided in job-level training and separately arranged training on legal and regulatory matters. In fiscal 2015, we held 3 workshops on Japan’s Antimonopoly Act, and 1 on the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors (the Subcontract Act). Through regular, ongoing measures such as these, UACJ Group strives to ensure sound compliance awareness and understanding of legal provisions throughout its organization.

Internal Reporting System (Corporate Ethics Consultation System)

The UACJ Group operates an internal reporting system (Corporate Ethics Consultation Hotline) the purpose of which is to prevent compliance problems altogether, or discover them early on and swiftly resolve them. This system has internal and external channels that employees can access anonymously. Measures are in place to receive contacts by telephone, postal mail, e-mail, and other means as well. The Anonymous Reporting Board*1 is another reporting function that we have established to make it easier for employees to report activity they believe or suspect constitutes a compliance violation. The Corporate Ethics Consultation Hotline oversees and appropriately handles all reports of questionable activity from the selection of a unit to investigate the report, to implementation of a formal response. At the same time, it makes clear to relevant employees that the reporting employee and those who cooperate with the investigation are not to suffer any negative consequences from the mere reporting of suspicious activity or cooperation with the investigation. Furthermore, actions are taken to thoroughly protect the reporting and cooperating employees by, for example, confirming that they actually have not been subjected to negative consequences for their actions.

*1 The Anonymous Reporting Board is a system that allows an employee to engage in a dialog anonymously with hotline personnel. The receipt of a report anonymously can make it impossible to adequately investigate the report or provide investigation results and information on problem solutions back to the reporting employee. The UACJ Group has adopted the Anonymous Reporting Board to alleviate such problems.

Hotline Reports Received and Status of Responses

In fiscal 2015, UACJ Corporation received four reports via the Corporate Ethics Consultation Hotline, while affiliates in Japan received a total of three. Of the total of seven reports, three concerned human rights, two were about labor-related matters, and the remaining two pertained to other matters. Reports from employees willing to provide their names were properly handled, and investigation results and information on corrective measures were provided to the reporting employees.

Reports from employees wishing to remain anonymous were investigated to the extent possible. Those engaging in the improper activity identified were instructed on proper approaches and cautioned regarding their conduct going forward.

Reports received by affiliates were properly responded to by the relevant company, with investigative and other types of assistance from UACJ Corporation, as needed.

Strict Compliance with the Antimonopoly Act and Protection of Free Competition

To promote fair, transparent, and free competition, and engagement in legitimate business transactions, the UACJ Group operates in strict compliance with the Antimonopoly Law. More specifically, the Group raised internal awareness of key points by providing detailed explanations of them in attorney-led presentations to all executives, the heads of all sales departments, heads of branch offices, and presidents of principal affiliates in Japan. Relevant points for sales employees at UACJ and affiliates in Japan were covered in workshops. Furthermore, to raise internal awareness of the need to avoid activity that may invite suspicions of cartel-like behavior, we have established a set of guidelines addressing matters prohibited as cartel-like behavior and points to be mindful of when coming into contact with people affiliated with a competing company. In fiscal 2015, we experienced no violations of either Japan’s Antimonopoly Act or the antimonopoly laws of other countries.

Anti-Corruption Initiatives

The UACJ Group explicitly prohibits actions such as bribery and excessive expenditures for entertainment in its Group Code of Conduct, and thorough understanding of these points is promoted in code of conduct education programs and job-level training. In fiscal 2015, Group Code of Conduct education materials were improved with the addition of examples of actions prohibited as either the acceptance or offering of a bribe.

There were no instances of the acceptance or offering of a bribe, or any other violations of the Group Code of Conduct, in fiscal 2015.

Rejection of Relationships with Antisocial Forces

In its company principles, the UACJ Group requires the strict rejection of relationships with antisocial forces and organizations. Furthermore, through our Group Code of Conduct, we strongly emphasize to all executives and employees that they are not to bend to inappropriate demands by antisocial forces, must remain resolute throughout, and must never engage in any relationship with antisocial forces.

UACJ, in accordance with its internal rules, makes donations and joins organizations only after determining that potential recipients, and organizations the company may join, have no connections to antisocial forces.