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Compliance

Basic Approach

The Link and Motivation Group strives to practice Management with Integrity (i.e., management with no illegality or dishonesty with regard to any of its stakeholders, including customers, business partners, employees and shareholders).
As a corporate entity, we abide by laws, regulations, corporate ethics and social norms, and understand that individual employees must also make efforts to avoid transgressions.

Compliance Framework

The Board of Directors is positioned as the highest decision-making body for determining basic management policies, important issues and key matters stipulated by laws and regulations. It meets once a month in principle. In addition, to enable swift decision-making and flexible organizational responses in business management, the Management Committee, which is attended by directors, the full-time Audit & Supervisory Board member, corporate officers and business heads, meets twice a month in principle.
Furthermore, to monitor business execution, ensure compliance with laws and internal regulations, and audit the appropriateness and effectiveness of business activities, Audit & Supervisory Board members attend Board of Directors meetings to confirm proceedings, procedures and other matters as needed.
Internal auditors conduct internal audits and regularly report the results to the Chairman and Representative Director and the President and Representative Director.

Compliance Training

To ensure thorough compliance among officers and employees, we regularly conduct training on information management, fair trade and related topics with the aim of enhancing knowledge and awareness.
We also administer compliance tests to assess employees’ awareness and understanding of compliance.

Internal Reporting System

We have established a contact point as part of an internal reporting system for the early detection and rectification of legal violations and other misconduct.
The contact point for consultations and reports regarding such matters is available for use by officers, employees (including full-time, part-time, temporary and dispatched workers), former employees (within one year after resignation) and workers at our business partners.
Anonymous reporting is also permitted, and we ensure the confidentiality of whistleblowers and prohibit any disadvantageous treatment on the basis of having made a report.
Reported matters are investigated by the full-time Audit & Supervisory Board member.
If misconduct is identified as a result of the investigation, measures to rectify the situation and prevent a recurrence are promptly implemented.
Disciplinary actions may also be taken against those involved in accordance with employment regulations.

Initiatives to Prevent Bribery

In conducting business both inside and outside Japan, the Link and Motivation Group recognizes the importance of raising awareness regarding bribery and implements initiatives to prevent any occurrence.
Our internal regulations prohibit, both directly and indirectly, giving, promising or offering money, goods, entertainment, benefits or any other advantages to public officials or other third parties for the purpose of obtaining improper advantage in business.
They also prohibit in principle giving any form of small facilitation payments.

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