Nurturing a culture of trust
Compliance/risk management system

Compliance System

1. With the recognition that intensive compliance is indispensable for the existence and continuity of a corporation, the Company established the Haseko Group Standards of Conduct in April 2003, under which Haseko has been working to establish a management system where all directors, operating officers and staff respect societal standards and take sensible courses of action in keeping with their duties as members of society, as well as complying with all laws and the Company's articles of incorporation, so that the Company can win the confidence of society. Moreover, for enhanced compliance Haseko established the Compliance Department which conducts promotion and education of compliance based on the internal rules and regulations on compliance. An internal whistle-blowing system for consultations on compliance and notification of illegal conduct, etc. and an external contact have also been established.
2. In April 2005, the Company established the Internal Auditing Department that is under the direct control of the President. Pursuant to internal rules and regulations on internal audits, the Department investigates and evaluates whether activities of respective divisions conform to laws and regulations, the Articles of Incorporation, the Company's rules and regulations, corporate policies, etc. and whether they are reasonable, and works to make improvements based on the results.
3. The Company has no relations with anti-social forces or groups that threaten the order and security of civic life, and will cope with such anti-social forces and groups systematically, and with an adamant and resolute attitude.

Haseko Group Standards of Conduct (Japanese Only) [PDF：218KB]

Risk Management System

1. In anticipation of a variety of risks, Haseko endeavors to collect risk-related information and prepares preventive measures and appropriate countermeasures in advance against risks according to their magnitude and possibility of arising. Through these efforts, Haseko aims to minimize the potential losses and to systematically cope with risk management centering on the Risk Management Department established in April 2006. 
2. Specifically, Haseko has set up a system in which respective sections of the Management Division coordinate with each other and check the status of business operations in accordance with the roles they are assigned, while the Internal Auditing Department conducts further checking. For the corporate approval system that serves as a record of decision-making for work implementation, the Company has introduced an electronic system in which legal procedures have been digitized since April 2002. This system enables auditors and the Management Division to view and check the content at any time. 
3. Furthermore, of the issues forwarded to the Board of Directors and the two operation councils (the Business Operation Council and Technology Operation Council), those involving many departments or requiring specialized knowledge are subject to sufficient verification in advance by the adequately established advisory meetings and committees. Periodical results reports are also mandatory for issues that require monitoring.
4. On top of these, the Company established the Risk Management Council under the chairmanship of the President in May 2006 with the aim of strengthening the risk management system of Haseko and its entire Group. This enhanced the Company's risk management system in which cross-sectional collection of information, analysis, valuation and handling of risks are conducted in accordance with the internal rules on risk management. In addition, the Company has appointed a Chief Risk Management Officer responsible for the overall risk management of its entire Group.
5. The contents of deliberations at the Risk Management Council are required to be reported to the Board of Directors on a periodic basis.

Establishment of a point of contact for whistleblowing and compliance consulting service

Haseko operates a consulting service for receiving reports and requests for advice from employees relating to compliance in general, which it has established in the Compliance Department of the Risk Management Department. Furthermore, in accordance with the Whistleblower Protection Act, Haseko has built a system to protect whistleblowers and operates a point of contact for receiving reports and requests for advice relating to acts in violation of laws and regulations, etc. that it has established in the Compliance Department of the Risk Management Department as well as in a law firm serving as an external point of contact.

Promotion of compliance

The Haseko Group has positioned ensuring the practice of compliance as one of its important management issues. In order to promote this, the Group has established the "Haseko Group Standards of Conduct" and ensures thorough compliance among all officers and employees. Furthermore, in order to keep all officers and employees well informed of the basic stance described in the Standards, the Group has distributed to all officers and employees the "Haseko Group Standards of Conduct" and the "Haseko Group's Compliance Rules and Regulations" including the "Haseko Group Compliance Manual" that explains each provision of the Standards of Conduct.

The "Haseko Group Compliance Manual" compiles specific items to be complied with related to matters including "compliance with various laws and regulations in the course of business (prohibition of bid rigging, cartel, etc.)," "prohibition of misconduct (prohibition of acts of conflict of interest, etc.)," "compliance with social standards (responses to anti-social forces, provision of gifts and entertainment to public officials, etc.)," "compliance with internal rules and regulations (prohibition of ultra vires acts, use of corporate assets, etc.)," and the Group has been making efforts to ensure thorough compliance and prevention of bribery and corruption.

Haseko Group Standards of Conduct

Haseko Group Standards of Conduct (Japanese Only) [PDF：218KB]

Our policy and commitment to prevent bribery and corruption

The Haseko Group has positioned ensuring the practice of compliance as one of its important management issues. In order to promote this, the Group has established the "Haseko Group Standards of Conduct" and ensures thorough compliance among all officers and employees.

Furthermore, in order to keep all officers and employees well informed of the basic stance described in the Standards, the Group has distributed to all officers and employees the "Haseko Group Standards of Conduct" and the "Haseko Group's Compliance Rules and Regulations" including the "Haseko Group Compliance Manual" that explains each provision of the Standards of Conduct.

The "Haseko Group Compliance Manual" compiles specific items to be complied with related to matters including "compliance with various laws and regulations in the course of business (prohibition of bid rigging, cartel, etc.)," "prohibition of misconduct (prohibition of acts of conflict of interest, etc.)," "compliance with social standards (responses to anti-social forces, provision of gifts and entertainment to public officials, etc.)," "compliance with internal rules and regulations (prohibition of ultra vires acts, use of corporate assets, etc.)," and the Group has been making efforts to ensure thorough compliance and prevention of bribery and corruption.

Business Continuity Plan (BCP)

The Haseko Group has formulated a "Business Continuity Plan (BCP)" or "Manual on Earthquake Disaster Countermeasures" for the purpose of developing: a mechanism of not only clarifying the key operations of Group companies in the event of a major earthquake or other natural disaster and ensuring the safety of "housing" provided by us, but also preventing the suspension of operations, or in the event that they are suspended, enabling the resumption of operations within the shortest time possible; and a mechanism of promptly preserving offices and tasks after ensuring the safety of employees and their families as well as enabling employees engaged in restoration activities and restoration support to take action autonomously. The BCP stipulates that it shall be triggered by the authority of general managers of divisions in the event where large earthquakes with a seismic intensity of 6 Lower or more are observed at an earthquake observation point of the Japan Meteorological Agency located within a 50 km radius of the Haseko Group's business bases (earthquakes below the reference seismic intensity are not excluded depending on the degree of the damage, etc.), and also in the event of natural disasters other than earthquakes (including storms, heavy rain, heavy snow, floods, high tides, tsunamis, eruptions, etc.) if the damage is significant.

The fiscal 2018 BCP drill for earthquake disaster countermeasures conducted in Tokyo, Kansai, Tokai and Kyushu regions from January to February 2019 focused on: (i) non-working day drill; (ii) drill for primary confirmation of conditions of disaster-affected properties using a map system; and (iii) a Group-wide emergency restoration instruction drill by determining an area heavily affected by disaster.