compliance
Policy/Basic Concept
SNBL is committed to corporate behavior in accordance with our corporate philosophy of "We will continue to be a company that values the environment, life, and human resources," respects social norms, complies with laws, regulations, and internal rules, and fulfills our corporate social responsibilities required by society.
The Company has formulated theSNBL Compliance Code of Conduct, which sets forth the principles of conduct of each Group company and the basic code of conduct for the Group's officers and employees. In accordance with the Compliance Code of Conduct, we strive to foster a corporate culture in which each and every officer and employee fully understands the significance of compliance and can act in accordance with compliance not only in corporate activities but also in social life.
SNBL Compliance Code of Conduct
In 2004, we formulated theSNBL Compliance Code of Conduct with the aim of accurately recognizing and understanding laws and regulations and internal rules, complying with them, and acting with high ethical standards in the course of our corporate activities.
This guideline establishes a code of conduct that is sought as a member of theSNBL Group from the perspective of five stakeholders: "Relationship with Society," "Relationship with Customers, Business Partners, and Competitors," "Relationship with Shareholders and Investors," "Relationship with Employees," and "Relationship with the Company and Company Assets."
Compliance education and awareness activities for employees
Our company group conducts compliance training for all employees. We provide e-learning-based corporate code of conduct education every month to all executives and employees, including contract and part-time workers. In addition to reviewing the content of each provision of the compliance action guidelines, we cover topics aligned with the enforcement of laws and regulations, and incorporate real-world examples from outside the company to enhance employees' compliance awareness.
Internal Audit
Regarding internal audits, we have established an independent organization, the Internal Audit Department, which conducts objective regular audits in accordance with internal audit regulations. These audits target our company and consolidated subsidiaries from the perspectives of risk management, operational effectiveness and efficiency, compliance, and appropriate financial reporting.
Regarding the audit results, we report the audit to the president through a written document, and every month, we directly report on activities and results to the board of directors and all auditors. For the audited departments, we issue improvement instructions based on the audit results and ensure the effectiveness of internal audits by having them submit the results of their improvement activities as an improvement report.
Plans, contents, and results of internal audits are shared through regular meetings between the Internal Audit Department and the auditors, and a system is in place to receive suggestions and guidance for improvement from the auditors.
The auditors, accounting auditors, and internal audit department regularly exchange information on matters that need to be shared, including regular meetings for annual schedules, and the auditors can request the accounting auditors and internal audit department to attend the board of auditors meetings as necessary, thereby enhancing mutual collaboration.
Whistleblower System
Based on our corporate philosophy, we have established the "Internal Reporting and Retaliation Prohibition Policy" with the aim of ensuring compliance management, and we have developed an internal reporting system to prevent misconduct, detect it early, and correct it.
As a reporting reception desk, the 'Helpline Reception Desk' is established both inside and outside the company, with reporting methods such as telephone, email, written documents, and meetings in place, and it is made known to officers and employees. The officer in charge of the internal reporting system is responsible for its operation.
Consultation and Reporting System from Outside the Company
Our company has established a contact point for consultations and reports regarding legal violations, fraud, etc., by employees in transactions with our business partners.
The consultation and reporting content is received by the internal audit department directly under the chief management officer, and a system is in place to respond in accordance with company regulations. The results of the response will be communicated to the consultant or reporter with full consideration of the privacy of those involved. At that time, the name of the reporter and the facts and content of the consultation or report will not be disclosed to anyone other than those involved in the investigation.
Anti-Bribery and Anti-Corruption
Our company has established a "Policy on the Prevention of Bribery and Corruption." We declare our commitment to approach with a high sense of ethics, not allowing any violations against bribery and corruption, and we require our officers, employees, and business partners to refrain from any acts of bribery and corruption and to ensure free and fair competition. In compliance behavior guideline training, we strive to raise awareness within the company and prevent occurrences by introducing external cases related to bribery and corruption that have actually occurred.
In order to appropriately respond to laws that prevent fraudulent transactions by companies, we are working to prevent the occurrence of fraud in collaboration with experts such as lawyers.
Preventing insider trading
Our company has established the 'Insider Information Management Regulations' and complies with the insider trading regulations stipulated by the Financial Instruments and Exchange Act, as well as internal company rules.
In compliance behavior guideline training, we introduce external cases of actual insider trading to raise awareness within the company and work to prevent occurrences.
Prevention of conflicts of interest
In accordance with the "VI. Relationship with Company and Company Assets 3. Prevention of Conflicts of Interest" stipulated in the "SNBL Compliance Action Guidelines," the Company strives to ensure the legality and transparency of the Company's transactions, etc., in accordance with the procedures prescribed by laws and regulations in order to prevent damage to the Company due to inappropriate conflicts of interest.
In the compliance behavior guideline training, we introduce external cases related to actual profit solicitation activities to promote awareness within the company and prevent occurrences.
Severing ties with antisocial forces and organizations
The Company stipulates in the "SNBL Compliance Action Guidelines" that "II. Relationship with Society In accordance with 4. Severance of relationships with antisocial forces and groups, we are engaged in preventive activities such as including anti-exclusion clauses in various contracts with business partners.
As a company, we have established a system to respond promptly and appropriately to contact from antisocial forces by collaborating with the police, legal advisors, and other external organizations.
Tax Governance
Our company has formulated a 'Tax Policy' and strives to minimize tax risks and achieve high transparency in taxation by complying with tax-related laws and regulations and making appropriate declarations.
Tax Policy