Basic approach
In our Declaration of Conduct and Standards of Conduct, our sets of values and action guidelines that all officers and employees should share, we stipulate that Credit Saison shall comply with all laws and regulations and take a firm stand against any behavior that deviates from these rules. We comply with laws and internal rules and carry out our business activities in an appropriate manner in all cases, aiming to enhance our corporate value and achieve sustainable growth while earning the trust of our stakeholders. We will continue to comply with the laws of countries where we operate and will strive to raise our individual employees' awareness of compliance.
System
To promote compliance in a Group-wide manner, we have established the Compliance Committee, which is chaired by the officer responsible for Corporate Risk Management Dept. Activities of the Compliance Committee include approval of the Group-wide compliance promotion plan and training plan, reporting on their progress, and reporting on the status of compliance with each law and regulation. We have also assigned compliance officers and compliance staff in the respective departments. They are promoting compliance in their departments.
These initiatives are reported to the Board of Directors on a regular basis. The Audit Department audits the effectiveness and efficiency of business execution in each department and reports to the Board of Directors and the Representative Director.
Education and fostering awareness of compliance
We believe that we must comply with laws and regulations in the fulfillment of our duties and ensure our actions are consistently aligned with social norms to earn society's trust and achieve a sustainable increase in corporate value.
Based on this belief, we have established our Management Philosophy, Declaration of Conduct, and Standards of Conduct as fundamental compliance policies. In line with these policies, we ensure that all employees are informed of the laws and regulations that they must follow, and we provide employees with training so that we are able to maintain and enhance our compliance posture.
Specifically, we conduct compliance training programs every year based on an officer and employee training plan to enhance their understanding of the importance of legal compliance and social responsibility. These programs encourage each individual employee to increase their own awareness and change their behavior, fostering a cycle for the continuous improvement of compliance.
＜Example components of training programs＞
- Basics of compliance
- Measures to combat money laundering and Act on Prevention of Transfer of Criminal Proceeds
- Act on the Protection of Personal Information
- Money Lending Business Act, and Installment Sales Act
- Prevention of bribery and corruption
- Act on Prohibition of Private Monopolization and Maintenance of Fair Trade (the “Antimonopoly Act”) and Unfair Competition Prevention Act
- Act against Unjustifiable Premiums and Misleading Representations
- Intellectual property law
- Whistleblower system
Internal reporting system
The Company and each individual Group company has established a whistleblower system to ensure compliance and uphold a high standard of corporate ethics. This system is a significant mechanism for identifying harassment and other misconduct at an early stage and promptly and appropriately implementing corrective measures.
Reports can be made through an internal hotline or an external law firm. Employees can report via email or post, either using their real name or anonymously. We have also set up an overseas hotline from affiliated companies locating overseas. The hotline can be used in the language of each country, and consistent service is provided regardless of location.
This system is accessible not only to Group employees but also to the diverse range of individuals involved in our businesses, including the employees of trade partners, freelancers and job seekers, and former employees. Regardless of the severity of their unique issue, these individuals can consult on various issues regarding the violation of laws, regulations or internal rules, prevention of bribery, and corruption, the various types of harassment and other actions that violate social norms or our corporate ethics.
We will ensure that whistleblowers will not suffer any disadvantage for reporting, and the confidentiality and personal information of whistleblowers is managed strictly. The Compliance Committee receives regular updates on the operational status of the system, and training sessions and internal awareness campaigns are implemented to enhance its effectiveness, including training sessions for Company employees focused on teaching appropriate ways to respond to various compliance issues, including harassment, using specific examples.
Response to Money Laundering and Terrorism Financing
To prevent money laundering and terrorism financing, the Company has established internal rules to ensure compliance with relevant laws, regulations, etc. and has put in place a system for implementing preventive measures.
It implements risk mitigation measures, such as filtering transactions at the time of business deals, in addition to identity verification based on relevant laws and regulations, and monitoring of transactions on a periodic basis after contracts are concluded.
It also strives to reinforce the system by improving employees’ knowledge by holding regular internal training sessions.
Response to anti-social forces
It is stipulated in our basic policy on measures against anti-social forces that we reject any relationships with anti-social forces, which threaten public order and social safety through organized crime, terrorist financing and other conduct, and maintain a firm attitude against them. We keep our employees thoroughly informed of this policy through regular training and other initiatives. When we start a new transaction or enter a similar situation in any of our businesses, we conduct sufficient investigations as to the level of social credibility of our trade partners and include a clause on the elimination of organized crime groups in the contract, so that we can cancel the contract ex-post facto if the trade partner should turn out to be anti-social forces.
Appropriate Management of Personal Information
ー Basic approach for handling personal information
The Company understands that one of its critical responsibilities is the proper management of personal information.
We comply with laws and regulations, including the Act on the Protection of Personal Information, as well as related guidelines and industry rules.
We have implemented internal regulations to maintain and improve our protection of personal information.
ー Initiatives to protect personal information
With regard to the handling of personal information, we have implemented appropriate management measures, including using dedicated lines, restricting access to authorized personnel only, encrypting information, and controlling access to and from information terminal locations. We also comply with the PCI DSS, a global security standard in the credit card industry, for our Associated Core System and other systems that handle important data, such as customer credit card information.
In May 2006, we obtained Privacy Mark certification, which is granted to businesses that handle personal information appropriately.
We handle personal information properly in accordance with our privacy policy.
Prevention of Bribery and Corruption
The Company's Basic Policy on Prevention of Bribery and Corruption prohibits any form of bribery and corruption. This policy applies to all officers and employees. To implement this policy, we focus on training and raising awareness about measures to prevent corruption, particularly bribery. We publish our internal rules on bribery and corruption prevention on our intranet to ensure all employees are informed of them.
・Political donations
We do not make political donations.
・Ant-corruption initiatives
We are dedicated to strictly following internal rules regarding bribery and corruption prevention. We aim to promote awareness of the prevention of misconduct through the ongoing provision of training to officers and employees, contributing to the healthy development of society.
・Spending related to anti-corruption
There is no serious violation of laws or spending for penal charges or settlement related to corruption.
・Other
We have no expenditures relating to penalties specified in relation to ESG issues.
Ensuring compliance with the Antimonopoly Act and the Unfair Competition Prevention Act
The Company does not tolerate any actions that violate the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade or the Unfair Competition Prevention Act, including cartel and bid rigging activities. We have established internal rules related to relevant laws and regulations, and the Act against Unjustifiable Premiums and Misleading Representations, the Act on Preventing Delay in Payment to Small and Medium-Sized Entrusted Business Operators in Relation to Manufacturing Consignment, and the Act on Ensuring Proper Transactions Involving Specified Entrusted Business Operators, and we have developed a systematic compliance system. We will provide ongoing compliance training to increase officers and employees' awareness of compliance. We will also work to prevent compliance violations in advance and respond promptly to any that occur.
Prevention of insider trading
To prevent insider trading or similar misconduct, the Company has set out rules on the management of insider information obtained by our directors, executive officers and employees in relation to their duties and standards of behavior, in our insider trading rules, thus managing insider information strictly. We regularly provide training for all employees to prevent insider trading and other similar activities.
Internal rules on generative AI
Our initiatives related to the utilization of generative AI
In light of the risks linked to the use of generative AI in business, including information leaks, rights infringement and misinformation, the Company has established its Internal Rules on Generative AI and is promoting the safe and responsible use of generative AI. We prohibit inputting personal information, confidential information, and third-party copyrighted material into generative AI applications, in principle. We also require fact checking and verification to ensure that generated content does not infringe on copyrights. We also ensure that our outsourcing partners and collaborators have the same policies for using generative AI, and we work with them to maintain unified standards throughout the supply chain.
Tax policy
ー Basic policy
We pay taxes appropriately by complying with the tax-related laws and regulations of each country and region where we operate. We understand that an appropriate tax payment contributes to the economic and social development of each country.
ー Measures related to Base Erosion Profit Shifting (BEPS)
We do not avoid tax intentionally by making use of tax incentives with measures not involving actual business activities or by using locations deemed to be tax havens.
International deals between Group companies are made by observing the OECD Transfer Pricing Guidelines.
ー Relationship with tax authorities
We provide information to tax authorities appropriately and respond to them faithfully in our efforts to build a sound relationship with them.
ー Management system
We have a governance structure in which the CFO assumes ultimate responsibility. The heads of responsible departments report the status of accounting and tax affairs appropriately.
People in charge of tax affairs consult external tax advisers in a timely manner in their efforts to ensure appropriate tax processing and reduce tax risk.
