Compliance

Basic Approach

KOITO positions the reinforcement of compliance as one of the most important aspects of its administration to continue as a company that is trusted by all stakeholders. To foster an organization and atmosphere to place importance on compliance, the entire KOITO Group is committed to engage in compliance activities based on the KOITO Group Corporate Behavior Charter.

Compliance Management Structure

KOITO has formed the Compliance Committee chaired by the President to improve compliance. The Compliance Committee establishes a Compliance Policy, supervises the appropriate operation of corporate ethics consulting desk, and determines measures for preventing a recurrence in case important compliance issues occur.
 Compliance managers and staff in charge are also appointed at the subsidiaries inside and outside Japan to keep track of the compliance status in close collaboration among them. KOITO is thereby engaged in compliance activities in the entire group.

Anti-corruption Initiatives

Based on the KOITO Group Corporate Behavior Charter, KOITO is promoting initiatives to prevent bribery and other compliance-related activities.
 Through the "Anti-bribery Regulations" and internal education, KOITO is working to prevent corruption, such as bribery, extortion, fraud, embezzlement, money laundering, conflicts of interest, illegal financing to political parties, and the prohibition of facilitation payments.
 The Anti-bribery Regulation stipulates that a notification shall be made to the Compliance Department with respect to the approval procedures for entertainment, etc.
 The amount of penalties imposed in the event of violations is stipulated in our internal regulations.
 There were no infringements in fiscal 2020.

Prevention of Anti-competitive Practices

Based on the KOITO Group Corporate Behavior Charter, KOITO is promoting initiatives to prevent bribery and other compliance-related activities.
 Through the "Anti-bribery Regulations" and internal education, KOITO is working to prevent anti-competitive practices, such as market-sharing, abuse of dominant position, dumping, and price-fixing.
 KOITO conducts annual audits of organizations that have the risk of anti-competition practices. When discovering suspicious practices during internal audits, we conduct investigations and strive to clarify the truth.
 The amount of penalties imposed in the event of violations is stipulated in our internal regulations.
 There were no infringements in fiscal 2020.

Whistle-blowing System

KOITO has set corporate ethics consulting desks within the company and outside (law office) as a place where employees can report and consult about violations of laws or regulations in business activities. Regarding the contents of the reports, we investigate and consider remedial measures as necessary and report them to the Compliance Committee.
 The protection of whistle-blowers is ensured in the operation of the whistle-blowing system. Also, information with which whistle-blowers can be identified is put under strict management. KOITO also prohibits the dismissal of or disadvantageous treatment of whistle-blowers for the reason why they have reported to the corporate ethics consulting desk.

Compliance Education

KOITO provides various compliance training for different roles and job duties. For employees, KOITO provides education on compliance in the job-rank based training. KOITO also offers training in other fields, such as the Antimonopoly Act, the Subcontract Act, and harassment. Compliance training is also provided to Directors and Corporate Officers by inviting instructors from the outside.
 In addition, KOITO provides compliance education to suppliers. KOITO asks them to ensure compliance at the annual procurement policy briefing session. Compliance training sessions targeting suppliers are also conducted when necessary.

Reinforcement of Compliance

Besides the KOITO Group Corporate Behavior Charter, KOITO has established internal regulations related to important laws and regulations, such as the prevention of bribery, the Antimonopoly Act, and protection of personal information.
 The KOITO Group Corporate Behavior Charter is printed on portable cards and distributed to all employees for use as the guideline for their actions and to enhance their awareness of compliance. Surveys targeting all employees are conducted every year to measure their knowledge and understanding of the Charter. Results are then reported to the Compliance Committee.
 
KOITO has developed bribery prevention regulations to make sure laws and regulations are thoroughly followed within the entire group.
 Internal regulations related to the Antimonopoly Act and the Subcontract Act are developed to ensure compliance and prevent violative act. The Internal Audit Department regularly conducts on-site audits to all relevant departments every year and reports its findings to the Compliance Committee.
 
Due to the steady efforts to enrich compliance systems and training among other measures, no penalty or fine for engaging in bribery was imposed on KOITO in FY 2020. KOITO did not make any political donations. No KOITO employee was fired for compliance violations, neither. The entire KOITO Group will continue to reinforce the compliance system.