Governance and Risk ManagementCompliance

Compliance Structure of Tokyo Century Group

Based on the awareness that thorough adherence to compliance is essential to the continued existence of a company, Tokyo Century Group strives to ensure the establishment of a system of management which will be trusted by society at large and in which all officers, managers, and employees act based on a just and high sense of ethics.

In Tokyo Century Group, the President & CEO of Tokyo Century Corporation heads the compliance of the entire Group as the Chief Compliance Executive Officer, and the Compliance Office plays a role in exercising, promoting, educating and reviewing compliance matters across the entire Group in accordance with compliance programs under the supervision of the Chief Compliance Officer (CCO) who is appointed by the President & CEO.
At each organizational group, such as divisions and branch offices, the head of each group acts as the Compliance Officer (CO) to take responsibilities for promoting compliance awareness of each own group, including handling compliance matters and carrying out compliance trainings in collaboration with the Compliance Office.
At our consolidated subsidiaries, the President or an officer equivalent to president acts as head of compliance, in order to take control of building, maintaining and managing the compliance of each subsidiary through the instructions, guidance and advices from CCO. As for non-consolidated group affiliates, the Compliance Office gives guidance and advices on compliance structural management in a timely manner.

We report and review the Group’s compliance structure and operation at the Management Meeting every half year for review. Based on the results of the review, we make and implement compliance promotion plans. Apart from this, we oblige all the officers and employees to submit a compliance pledge once every year in order to comply with our compliance regulations.
Note that as of March 31, 2018, there have been no major compliance violations deserving of public announcement.

【Compliance Structure of Tokyo Century Group】

Compliance Structure of Tokyo Century Group

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Compliance Handbooks

Tokyo Century Group distributes our Compliance Handbook to all officers, managers, and employees while providing it on our corporate portal at all times. The Compliance Handbook includes information on internal regulations such as our management philosophy, scope of corporate activities, and compliance management regulations, as well as information on matters such as prohibitions against respect for human rights and harassment. The Group also strives to improve the compliance mindset at our local subsidiaries overseas and has created an English and Chinese edition of the handbook for these companies.

Compliance Handbooks

Compliance Education

Aiming to ensure the thorough dissemination of a compliance-oriented mindset, Tokyo Century Group provides systematic and continuous compliance education through such means as rank-based training from new hires to newly appointed managers; e-learned-based training to all officers, managers, and employees; and compliance training to divisions and branches conducted by compliance officers.

Compliance Training during Fiscal 2017

Targets Subjects Implemented
New employees
(rank-based training)
  • Meaning and significance of compliance
  • The proper mindset in regard to laws and internal rules
  • Compliance determination
  • Compliance-conscious actions
  • Tokyo Century Group’s internal reporting system
  • Information security rules, countermeasures and others
  • Threat posed by information leakage and countermeasures
  • Cyberattacks and other issues
April 2017
All officers and employees
  • Revised Personal Information Protection Law
  • Tax compliance
  • Working hour management
  • Sexual harassment
June 2017
New managers
(rank-based training)
  • Management and compliance
  • Psychology and causes of legal violations in the context of risk management
  • Proper labour management
  • Prevention of power harassment
  • Potential compliance risks in the workplace
  • Honing compliance sensitivity, and other issues
June 2017
All officers and employees
  • Insider trading regulations
  • Severing ties with antisocial organizations
  • Role of compliance officers (all heads of divisions and branch offices) and the internal reporting system
  • Prohibition against bribery of foreign government officials
  • Prohibition of harassment, and other issues
February 2018
Compliance officers /
All heads of divisions and branch offices
(Leaning knowledge and information of compliance)
  • Internal reporting system and management of information assets
  • Corporate bankruptcies due to compliance violations
  • Harassment (definition, case examples, handling of the cases and control policy of harassment), and workplace penalty system
  • Personal Information Protection Law – Basics/Applied courses
  • Insider trading regulations
Six times per year
Additional training provided by
all heads of divisions and branch offices

Internal Reporting System

At Tokyo Century Group, in the aim of early detection and resolution of risks, organizational self-cleansing improvement and enhancement of its compliance management, we have established an internal reporting system “Consultation/Whistle-Blowing System”, whereby officers and employees who become aware of acts of compliance violations being conducted or about to be conducted are obliged to directly report such matters without the intervention of their superiors.

(1) Outline of the Internal Reporting System

We have established three reporting routes as reporting desk: the in-house Compliance Office; the corporate lawyer’s office which is familiar with this field outside the company; and full-time corporate auditors in order to ensure independence and allow reporting persons to choose any route among them.
Reports can be sent by any way, such as by email, telephone, verbally or written form to the contacts which are stated in the Group’s Compliance Handbook that were distributed to all officers and employees as well as posted on the Company’s intranet.

Matters subject to reporting vary in a wide range, such as violation of the Anti-Monopoly Act or bribery that impedes fair competition, violation of the Financial Instruments and Exchange Act that undermines profits of investors and others, and human-rights violations, violation of any laws concerning business operations, or misconduct which is against corporate ethics or internal rules.
In addition, the reporting system also covers the consultation when there is any doubt about compliance in terms of business execution.

All officers and employees are eligible to report such matters through this reporting system, including directors, officers, permanent employees, contractors, temporary staff, seconded employees, part-time staff and retired employees, even by remaining anonymous.
We strictly prohibit disadvantageous handling, such as disciplinary action, retaliation and others to the reporters for raising concerns by the Company, and secure anonymity of the reporter and keeping confidentiality concerning the report.

(2) Implementing Survey on Reported Matters

Receiving a report, the reported matters are discussed with the CCO to take necessary actions and promptly conduct a survey to find out the facts.
On that occasion, we impose confidentiality obligation on personnel involved in the survey and personnel subject to a survey, and prohibit unfair treatment of the personnel subject to the survey as same as the reporters to prompt them to cooperate in the survey.

Survey results are reported to the CCO, and if the survey results reveal a compliance violation, recurrence protection measures and other necessary measures are implemented while working on to correct the compliance violation and prevent expansion of losses.
Critical compliance violations are reported to the Chief Compliance Executive Officer of Tokyo Century Group (President & CEO of Tokyo Century Corporation), and the Corporate Auditors.

Anti-Corruption Efforts

At Tokyo Century Group, we take an initiative to avoid anti-corruption through endeavoring to engage in fair, equitable and transparent transactions in any of our operating activities.

Tokyo Century Group prohibits offering entertainment, cash or any other benefits to domestic or overseas public officials in purpose of obtaining illicit profit, rewarding them for granting of favors or obtaining unfair business advantage either in direct or indirect through agents, consultants or any other third parties.

We have established “Guidelines on Offering Entertainment to Public Officials” in Japanese, English and Chinese languages to ensure raising a group-wide awareness, including national staff in our overseas local subsidiaries.

Furthermore, in order to contributing to realizing a safe society and conducting healthy economic activities, the Group has set out and implemented various measures, including identification confirmation before concluding agreements with business partners to prevent money laundering and financing of terrorism that may foster organized crime.

Our commitment to anti-corruption efforts are specified in our compliance handbook while including them in in-house trainings, primarily e-learning and others from time to time, in order to fully spread to all managements and employees group-wide.

At Tokyo Century Group, we report anti-corruption efforts at management meeting and board of directors for review as part of its compliance structure and operation.


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