Group Code of Conduct
The Group Code of Conduct was created based on the Corporate Philosophy and the principles of the UACJ Way to provide guidelines for employees and officers to follow in their conduct. The Code of Conduct is included in rank-based education programs as part of our ongoing and regular programs to familiarize employees with the code and to promote awareness of compliance and understanding of laws and regulations.
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 2022, department-level seminars on the Group Code of Conduct were held for employees of UACJ, 22 Group companies in Japan and 22 Group companies overseas. Afterward, the president of each company pledged to the President of UACJ in writing that they would uphold the Group Code of Conduct.
Training was conducted on topics such as information security, Japan’s Personal Information Protection Law, and the EU’s General Data Protection Regulation (GDPR). In addition, in fiscal 2022, following the enforcement in the previous fiscal year of the Revised Act on Comprehensive Promotion of Labor Measures, we paid special attention to the topic of power harassment.
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
The UACJ Group operates an internal reporting system 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. We also provide a cloud-based internal reporting system to make it easier for employees to report activity they believe or suspect constitutes a compliance violation. The unit in charge of the internal reporting system 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.
In addition, as recommended in guidelines issued by Japan’s Consumer Affairs Agency, we have established a common contact point for use by Group executives and rank-and-file employees inside and outside Japan to make our reporting system even easier to use.
Consultations and reports on compliance issues are accepted not only from current but also retired/resigned officers and employees (within one year after retirement or resignation).
* The cloud-based internal reporting system 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 2022, UACJ Corporation received 12 reports via the Corporate Ethics Consultation Hotline, while affiliates in Japan received a total of 25. Twenty-five of the reports concerned harassment and 12 concerned 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 the Company, as needed.
Strict Compliance with the Antimonopoly Act and Protection of Free Competition
As a step for ensuring that the UACJ Group engages in competition that is fair, transparent, and free, and business transactions that are legitimate, we have established the UACJ Group Basic Policies and Rules for Competition Law Compliance to strengthen our systems for compliance with competition laws in Japan and abroad. Along those lines, we have also set forth in the UACJ Group Code of Conduct provisions prohibiting restraint of competition, abuse of advantageous circumstances, and other such activities. We promote understanding of these topics in training on the code of conduct, job-level training, and on other occasions as well, and have established a consultation contact point for employees to communicate questions and concerns.
No violations of either Japan’s Antimonopoly Act or the antimonopoly laws of other countries occurred during the fiscal year.
The UACJ Group has taken actions to ensure that it engages in fair, transparent, and appropriate business transactions, and to strengthen our efforts to prevent the payment or receipt of bribes. These actions include establishment of the UACJ Group Basic Policies and Rules on Bribery Prevention, inclusion of provisions specifically prohibiting acts such as bribery and excessive expenditures for entertainment in the Group Code of Conduct, and promotion of thorough understanding of these matters in code of conduct education programs and job-level training. We have also created a contact point for employees to ask questions and express concerns.
Seminars on bribery prevention were held for department heads and newly appointed managers as a part of the regular annual training regimen.
There were no instances of the acceptance or offering of a bribe during the fiscal year.
Rejection of Relationships with Antisocial Forces
In its UACJ Way, a set of shared principles of conduct, the UACJ Group sets forth safety and compliance as fundamentals for its business activities. Furthermore, in the UACJ Group Code of Conduct, we make clear to executives and employees that inappropriate demands by antisocial forces are to be met with resolve and not to be accepted under any circumstances, and that all relationships with antisocial forces must be rejected.
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.