immoC■ Compliance promotion systemynapmoc fodraoBtnemtnoppa/noissisrotidua/noitatlusnoCnoitacfiiton40Risk management and compliance are among the top corporate management issues. We have established proper management systems through various means, including having respective sections or departments establish relevant regulations and manuals to ensure that they are thoroughly communicated and understood by employees. Furthermore, to promote compliance management practices, we revise the Compliance Manual in response to the changing social environment and take steps to ensure thorough communication to and the understanding of all employees.To respond to companywide risks, we have established the Risk Management Committee, chaired by a managing executive officer. This body determines annual priority risks to be managed by top management, based on conceivable potential risks; undertakes quarterly inventory/evaluations and revisions; and acts to ensure thorough communication to and understanding by all employees. For annual priority risks, risk management measures are planned and implemented for individual risks, incorporated into operational processes, and adjusted and coordinated among different sections and departments.The management status of these priority risks are reported to the top management by the various sections and departments. The Crisis Management Regulations specify how to anticipate risks and respond to any risks that manifest to preserve corporate assets minimize consequences for business management.Our Compliance Committee, chaired by an executive vice president in charge of compliance, formulates compliance promotion plans and supervises actions concerning corporate ethics, including legal compliance. It also establishes Anti-monopoly Legislature Compliance Rules and Collusive Bidding Prevention Manual and undertakes continuous education/training for the relevant personnel to enhance our actions against any collusive biddings. It also establishes Insider Trading Prevention Management Regulations for effective prevention of insider-trading.In accordance with the enforcement of the 2006 Whistleblower Protection Act, a reporting contact office was set up and an internal reporting regulation established to make efforts to implement and improve activities and systems to raise awareness of the whistleblower system.The TOBISHIMA CORPORATION Code of Conduct stipulates the elimination of all ties to any anti-social forces. The Crisis Management Regulations and the Anti-social Forces Handling Manual set forth how to handle various situations and establish organizations in charge, including the appointment of a manager in charge of avoiding unjustifiable demands. We also enhance joint efforts with specialized bodies and lawyers, etc.We share information about anti-social forces to ensure that all employees are fully aware of how to handle them. When concluding contracts, we constantly include provisions concerning the elimination of organized crime syndicates.We implement compliance e-learning via the intranet for all implement compliance officers and employees. We also education in various ways, including new employee orientation and group training according to status and business division.To further promote compliance, we publish the monthly Compliance Communication as a compliance promoting document to raise employees’ awareness of compliance.Basic approaches to risk management & complianceRisk Management CommitteeCompliance CommitteeShareholders (Shareholders’ Meeting)Board of DirectorsPresidentCompliance officer (officer in charge)Compliance CommitteeCompliance departments(Compliance Management Department, Internal Control and Audit Office)Report/consultationControl manager of department compliance(Headquarters/branches/group companies)Report/consultationEmployees, etc. (full-time company staff/contract employees/dispatched employees/part-timers, etc.)ReportAuditWhistleblower systemActions to eliminate anti-social forcesCompliance trainingRisk Management and Compliance
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