Compliance
Basic Philosophy
In its Basic CSR Policy, which is the basic philosophy of the Group, Socionext Group recognizes that "Compliance with Laws and Regulations, and Social Standards ", "Promotion of Fair Business Transactions" and "Confidentiality" are important responsibilities. Based on these Basic CSR Policies, the Group has established the Compliance Code as part of our Group regulations, and we ensure that all Group employees act with a high sense of ethics and compliance awareness. Violations of these regulations are subject to disciplinary action in the Work Rules.
| Compliance Standards (excerpted) |
|
|---|
Compliance Administration
●Risk and Compliance Committee
Our group has a Risk and Compliance Committee made up of executives and others and led by the CEO. The committee meets once a quarter to assess, analyze, and formulate actions on issues such as compliance, information security, and disaster risks.
●Internal Reporting System
Our group has established an internal reporting (Whistle-Blowing) system for the early detection and response to unauthorized activities that is intended to reinforce fair business practices that are in accord with the law. The system provides for both internal reporting (to the Socionext Risk Compliance Committee Secretariat/Full-time Audit & Supervisory Committee Member) and external reporting (to the Socionext Reporting Contact at TMI Associates). The diagram below shows a flowchart of how this works.
In accordance with the law and company policy on this issue, measures are in place to ensure that the persons making and receiving reports are not identified so as to prevent them from being subject to any unfavorable treatment. To date, the company has not received any reports of serious breaches of the law, CSR policies, or company rules.
[Internal reporting flowchart]
Main Actions on Compliance
●Promotion of Fair business transactions
In order to promote fair business transactions and anti-corruption measures, the Socionext Group has established the following Group Policy and is working on measures to ensure thorough dissemination. Since its inception, Socionext group has not violated any national competition, antitrust or anti-corruption laws.
(1)We conduct business transactions by fair means based on the principle of free competition and in compliance with national competition laws.
(2)We do not participate in agreements with competitors that may violate national antitrust laws and do not engage in practices that raise such suspicions.
(3)We comply with national anti-bribery and anti-corruption laws and do not engage in acts that invite such suspicion.
[Main measures]
We are working to prevent corruption by thoroughly disseminating rules prohibiting entertaining and giving gifts to public and foreign officials, applying in advance for entertaining and giving gifts, and conducting regular surveys on entertaining and receiving gifts.
All employees receive e-learning education, which includes explanations of relevant laws and regulations (Antimonopoly Law, Unfair Competition Law, etc.) and examples of violations, to continuously raise employee awareness.
Related Party Transaction Management Rules. The Company examines the reasonableness of transactions and the appropriateness of terms and conditions and eliminates inappropriate transactions such as conflicts of interest.
●Compliance education and Training
The Socionext Group conducts education and training to raise employee awareness and understanding of compliance.
The main instances of compliance education and training in the FY ended March 31, 2024 were as follows.
[Education and training]
Basic compliance education for all employees provided by e-learning (100% participation)
e-learning programs for all employees on the following topics (100% participation)
Laws on subcontractor payments and security-related export controls, harassment prevention, information security, and insider trading.
Group classes for new recruits on compliance, information security, and human rights
●Ensuring exclusion of Antisocial forces (organized crime)
The Socionext Group stipulates the exclusion of antisocial forces in its CSR policies and compliance criteria, explicitly declaring its intention to be resolute in its attitudes and response to all forms of antisocial activity and to avoiding such relationships, with this stance being clearly communicated to employees. The company has also formulated rules on dealing with antisocial forces and laid out specific measures for their exclusion.
[Key measures]
To ensure the exclusion of antisocial forces, provisions to this end are either included in supplier and other contracts or are contained in separate agreements reached with such parties.
Socionext cooperates with the Police and has put measures in place to collect information about antisocial forces. It has appointed a person to be responsible for preventing extortion and has joined an association of companies in Kanagawa for defending against such forces.
External agencies or similar are used to review all parties with which the company has contractual arrangements to determine whether they have connections with antisocial forces or are suspected of doing so, both at the time of entering into the contract and at regular intervals thereafter.
●Action on Preventing Insider trading
Socionext has formulated rules for preventing insider trading, with stipulations that include the appropriate handling of material information and the pre-approval and post-fact reporting of company shares. We also ensure that these rules are clearly communicated to employees. To ensure that insider trading does not occur, the rules have also been accompanied by an e-learning course for all employees to raise their awareness and understanding of the topic.