Corporate Ethics for Society, Human Rights, and the Environment


1. Actions complying with laws and regulations, social norms, and the Company Purpose

  • We comply at all times with all applicable laws and regulations, social norms, and regulations of our various group companies, and commit ourselves to strict business ethical standards.
  • We perform our work fairly and conscientiously, to keep the trust of society at large through our business and to help contribute to the creation of a society which will "open up individual potential through rewarding work" as set out in the Company's Statement of Purpose.

2. Protection of the natural environment and biodiversity

  • We conduct business activities which take into consideration the natural environment and biodiversity, recognizing that the creation of beneficial social value is another way to contribute to society.
  • We aim to achieve resource and energy savings, and strive for the creation of a sustainable society through such efforts as promotion of waste reduction, the 3 Rs (reduce, reuse and recycle), and the selection of goods that are friendly to the natural environment and biodiversity.
  • Protection of the natural environment and biodiversity inform our employee training, the auditing of our business relationships, and supervision by the Board of Directors.

3. Avoidance of relationships with anti-social forces and groups

  • We maintain a resolute attitude toward anti-social forces and groups, and do not enter into any unlawful or unethical transactions, including transactions with such forces and groups.
  • To avoid relationships with anti-social forces and groups, we conduct preliminary investigations before entering into a new transaction, educate our employees, audit business relationships, and ensure supervision by the Board of Directors.

4. Prevention of bribery

  • We do not give or receive bribes in the form of cash, gifts, donations, political contributions, or the like. We do not provide or receive business favors, not only when they are prohibited by law but also when they may influence business decision-making.
  • In order to prevent bribery, we conduct preliminary investigations before entering into a new transaction, educate our employees, audit business relationships, and ensure supervision by the Board of Directors.

5. Prevention of corruption

  • We do not engage in transactions that would distort market principles, and are not involved in any act, relationship or arrangement which gives rise or could give rise to a conflict of interest.
  • We conduct fair, impartial and conscientious transactions with stakeholders such as clients and contractors, and endeavor to coexist harmoniously and prosperously with them as a good business partner.
  • In order to preserve our trustworthiness, we maintain sound and transparent relationships, and do not engage in any action that could be considered collusive.
  • In order to prevent corruption, we conduct preliminary investigations before entering into a new transaction, educate our employees, audit business relationships, and ensure supervision by the Board of Directors.

6. Respect for individual human rights and individuality

  • We respect individual human rights and individuality, and do not conduct any actions that would infringe upon any human rights or result in discrimination, including discriminatory speech or behavior on the grounds of nationality, race, ethnicity, religion, creed, social status, family situation, age, disability, gender, sexual orientation or sexual identity; we do not tolerate violence, sexual harassment or power harassment.
  • If any action infringing upon an individual's human rights or individuality is discovered, we promptly take action to prevent a recurrence, while protecting the privacy of the affected person(s).
  • Respect for individual human rights and individuality informs our employee training, the auditing of our business performance, and supervision by the Board of Directors.

7. Appropriate employment and the work environment

  • In addition to complying with laws and regulations concerning employment and labor, we appropriately interpret social norms and decent work principles; we do not tolerate in any way child labor or slave labor; we do not vary employment conditions according to gender, nationality, etc.; our treatment of workers is based on the principle of equal pay for equal work; we do not treat workers differently on unreasonable grounds.
  • We maintain an employee-friendly work environment which gives due consideration to occupational health and safety, including on-the-job accident prevention, disaster preparedness, and promotion of mental health.
  • We respect the right of Officers and Employees to freedom of association and collective bargaining.
  • Appropriate hiring practices and a suitable working environment inform our employee training, the auditing of our business performance, and supervision by the Board of Directors.

8. Prohibition and prevention of insider trading

  • Unless required for reputable business purposes, we manage actions and information so as to not obtain insider information (including that of other companies).
  • We prohibit any actions providing a third party with insider information obtained in the course of work, and likewise prohibit its use to sell or purchase stocks, etc., or its use in other transactions.
  • The prohibition and prevention of insider trading informs our employee training, the auditing of our business performance, and supervision by the Board of Directors.

9. Thorough control over confidential information

  • We do not illegally obtain confidential information, including that of clients. In addition, we conduct management so that such information cannot be obtained or accessed.
  • strictly manage confidential information obtained during the performance of work so that such information is not used for an unintended purpose or provided or leaked to a third party without permission.
  • management of confidential information informs our employee training, the auditing of our business performance, and supervision by the Board of Directors.

10. Protection of personal information

  • We maintain a framework in which the personal information of job applicants, Officers and Employees, clients and others is handled appropriately in accordance with relevant laws and regulations, systems such as PrivacyMark, and social norms.
  • We strictly control personal information so that it is not used or obtained for an unintended purpose, or provided or leaked to a third party without permission.
  • In order to protect personal information, business companies of the Company obtain, in principle, certification under the PrivacyMark system (or its equivalent), and promote its aims through employee education, business performance audits, and Board of Directors supervision.

11. Protection of Company assets

  • We use Company assets, whether tangible or intangible, solely for appropriate business purposes, and avoid the confusion of corporate business with private affairs, such as using or expending such assets for a personal purpose.
  • The safeguarding of our corporate financial assets informs our employee training, the auditing of our business performance, and supervision by the Board of Directors.

12. Reporting of illegal actions and violations through the in-house whistleblowing system, etc.

  • We ensure that our in-house reporting (whistleblowing) system is thoroughly understood so that any person can submit a report through a channel different from the reporting line of the organization, when such person becomes aware of an illegal act referred to in this Code of Conduct, or a violation thereof.
  • Our management of information on persons who submit reports in good faith is appropriate for the situation, and we protect them by prohibiting retaliation against them, such as disadvantageous treatment in personnel affairs.