Compliance
Basic concept
The company has established the “Tsukishima Holdings Group Corporate Code of Conduct: Our Five Commitments” as a compliance code for all executives and employees, and we have established the “Tsukishima Holdings Group Corporate Action Guidelines” to describe principles of specific actions with which each and every member of the organization should comply. Practical details of the Corporate Action Guidelines are outlined via individual internal rules (including the Basic Rules on Protection of Personal Information, Rules on Management of Trade Secrets, the Antimonopoly Act Compliance Program, and Insider Trading Prevention Rules).
Group compliance structure
We have established a Tsukishima Holdings Group Compliance Committee, chaired by the President, Representative Director. The Director in charge of the Compliance Committee serves as deputy chair, while general managers of individual Tsukishima Holdings sections are appointed as members.
We also established a structure of three lines of defense for strengthening compliance. Through this structure, business sections (the first line of defense), administrative sections (the second line), and internal auditing sections (the third line) work with one another and serve as mutual checks and balances.
Progress
Compliance training
We provide compliance training for Group employees through in-person training, online training, e-learning, and other programs. In FY2024, training was provided on the themes of information security, the Antimonopoly Act, and harassment in the workplace. The participation rate approached 100%.
We have designated October of each year as Tsukishima Holdings Group Corporate Ethics Month, during which intensive awareness promotion activities are conducted to ensure that an understanding of compliance has been instilled throughout the organization.
Due in part to these activities, no cases of fines or employee penalties arose related to bribery and other acts of corruption in the Group.
Development of an internal whistleblowing system
To prevent or rapidly detect any actions that violate laws, regulations, or the articles of incorporation, in addition to an internal hotline and a hotline operated by a vendor specializing in receiving internal whistleblower reports, we appointed an outside attorney and the Company’s Full-Time Corporate Auditor to receive reports and conduct consultations through helplines.
The number of whistleblowing reports received in FY2024 was 15 reports, down six from the previous year. We respond to reports and consultations received by checking and investigating the facts of the matter and taking corrective measures as needed, while taking every step needed to safeguard the identity of the whistleblowers and comply with confidentiality obligations. Additionally, we analyze the reports and factual matters identified by the investigations and use the findings in e-learning and other compliance education to prevent recurrences.