ETHICAL BUSINESS MANAGEMENT SYSTEM

We conduct our business activities in compliance with the legal statutes and the spirit of the
law as an enterprise that practices ‘sound ethics and morality’ and respects the order of the
free competition market oriented to transparent fair competiton.

Summary

Fair Trade Practice Goals

Minimize risk related to fair trade

Autonomous Compliance Guidelines

Internal compliance program for autonomous compliance

It is an internal compliance program prepared and operated by a company to autonomously comply with the Fair Trade Act, and the will of the CEO and the operation of the program are included in the program It includes responsible organizations, manuals with checklists on management activities that violate the Fair Trade Act, education and training and counseling plans, internal audits, and measures to prevent recurrence.

Main contents

The Compliance Program is a voluntary practice program of a company and can be operated differently depending on the characteristics of each industry and company. However, in order for the Self-Compliance Program to operate effectively, it is necessary to meet the following seven key factors.

  • Implementation of an educational program
  • Preparation and distribution of the self-compliance manual
  • Designated operation of Self-Compliance Manager
  • Declaration of Management's willingness the establishment of a monitoring system
  • Declaration of Management's willingness the establishment of a monitoring system
  • Sanctions against executives and employees who violate fair trade laws
  • Establishment of Document Management System
  • Effectiveness assessment and improvement measures

Guidelines for Employee Behavior

  • Do not talk about prices and terms of transaction with competitors.
  • Do not share the market with competitors.
  • Do not attend meetings with competitors.
  • When a meeting with a competitor comes up with an agenda related to joint activities such as prices, he/she should leave.
  • Do not force the selling price.
  • Compliance with the guidelines of the Fair Trade Act's Self-Compliance Program.
  • If in doubt, consult with the CP manager of the compliance management team in advance