Compliance (environmental/social and economic)
Material Issue Compliance (environmental/social and economic)
- ●Violation of environmental laws and regulations: None
- ●Compliance with the political donation policy
- ●Order or recommendation due to violation of the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors (“Subcontract Act”) : None
- ●Violation of laws and regulations on security export control: None
- ●Information leakage: None
- ●Infringement of intellectual property rights: None
- ●Develop internal regulations reflecting the latest revision of laws, provide related education and conduct proper monitoring of the operation status
Raising awareness of compliance and promotion system
The Group has formulated and distributes to all Group executives and employees the Bando Group Code of Conduct, which stipulates proper actions in such areas as “compliance with laws and corporate ethics,” “product and service safety,” “honest and fair business activities,” and “fair and equitable procurement transactions.” In addition, the Group works to raise awareness of compliance by designating October as the Bando Group Corporate Ethics Month, holding briefing sessions on the Bando Group Code of Conduct at Company business facilities or domestic and overseas affiliates every other year, and providing opportunities to discuss these topics internally. Moreover, the Group has established a system to further promote compliance by adopting an internal reporting system that includes external lawyers as well as a service for providing information on the formulation, revision and abolition of relevant laws.
For environmental compliance, the Group conducts environmental assessment based on the environmental manual when installing facilities, adequate notification of facilities regulated by environmental laws and regulations and environmental measurement, employee education based on the “environmental management system” and the “environmental education manual.” In fiscal 2018, we conducted environmental patrols (twice for the Company, once for affiliates) and survey on the legal compliance status (once for overseas affiliates) to check whether domestic and overseas affiliates have carried out these activities adequately. In fiscal 2018, there was no violation of environmental laws and regulations resulting in material penalty or sanction. In fiscal 2019, we plan to set a month for making a concentrated effort to confirm management status and strengthen enlightenment, to conduct regular patrols for the prevention of environmental pollution and to make proposals for improvement of water treatment diagnosis systematically.
For socioeconomic compliance, the Group is working on the following initiatives: ensuring corporate ethics; prevention of insider trading and bribery/corruption; elimination of antisocial forces, clarification of political donations policy; compliance with the Antimonopoly Act and Subcontract Act; strengthening the security export control system; measures for information security; respect of intellectual property rights of third parties (including trade secrets); and amendments to labor-related regulations to reflect legal revisions and their dissemination. We also introduced the “reporting system for business partners” for early detection and correction of violations of relevant laws and regulations by the Group’s related parties. In fiscal 2018, there was no violation, infringement, leak, or breach in any of these matters.
- ● Violation: None
Carry “Group Code of Conduct” leaflet
In order to prevent corruption and anti-competitive behavior, the Group established the “Group regulations on legal compliance, etc.” and set up the “internal reporting system,” and also compiled rules to be complied with by officers and employees as the “Bando Group Code of Conduct” which officers and employees are required to carry with them. We also hold Code of Conduct workshops for officers and employees every year, hold lectures pertaining to the corrupt practices prevention laws for employees dispatched to overseas affiliates, and established and put into practice the “Group bylaw for compliance with the Antimonopoly Act” for the prevention of anticompetitive behavior. In fiscal 2018, there was no violation related to these matters.