1. Carlit Group Compliance Policy
Carlit Group company’s officers and employees act thoroughly in compliance with laws, regulations and internal rules, and take a resolute stance for the daily business with high ethical standards. Carlit Group makes every efforts to keep developing as a trustworthy business group.
2. Carlit Group Compliance Program
(1) Compliance Committee
Carlit Group establishes the Compliance Committee. The Compliance Committee deliberates important compliance matters related Carlit Group. Legal & Compliance Department is in charge of responding to any compliance matters in Carlit Group.
(2) Compliance Training Seminar
For the purpose of practicing fair corporate activities, Carlit Group conducts compliance training seminar every year for group companies, regarding various compliance matters, including antitrust laws and competition laws around the world.
(3) Internal Hotline System
Carlit Group establishes an internal hotline system for employees to report problems related to compliance, such as violations of laws and company regulations.
Carlit Group makes efforts for all Group employees to notice and understand the internal hotline system.
(4) Group Compliance Charter
Carlit Group establishes "Carlit Group Compliance Charter" as a basic code of conduct for all group officers and employees.
Excerpt from "Carlit Group Compliance Charter"
Article 1. Purpose
This Compliance Charter ("Charter") provides compliance items that all officers and employees of Carlit Holdings Co., Ltd. ("Holdings") and its subsidiaries (collectively with the Holdings, "Carlit Group") shall observe to contribute to society through acting soundly and carrying out their tasks with thoroughly complying with all applicable laws, regulations, company rules, Carlit Group codes and other social norms (collectively "Laws") in every scene of corporate activities.
Officers and employees shall realize the importance of observing this Charter, shall take the initiative of practicing this Charter, and shall act as responsible corporate citizen.
Article 2. Principles of action
Carlit Group shall observe Laws and shall perform sound corporate activities. Officers and employees shall always observe Laws and perform fair and transparent corporate activities in every scene of corporate activities.
Article 3. Respect for human rights and enhancement of workplace environment
Officers and employees shall respect human rights and shall strive to realize safe and delightful workplace environment without any discrimination or harassment.
(1) Respect for human rights
- Prohibition against discrimination and harassment
In all scene of corporate activities, officers and employees shall not engage in any acts of discrimination or harassment for reasons of race, creed, sex, age, religion, nationality, ethnic group, language, birth place, physical feature, disability, disease and others, and shall strive to maintain sound workplace environment.
- Respect for privacy and Protection of personal information
Officers and employees shall respect the privacy of other officers and employees, and shall properly protect and handle personal information with the most careful attention.
- Respect for personality and individuality and Fair personnel system
Carlit Group shall respect each officer’s and employee’s personality and individuality.
Carlit Group shall fairly evaluate job performance of officers and employees and operate fair personnel system to decide the transfer or promotion of officers and employees.
- Prohibition against harassment
Carlit Group shall prohibit any harassment such as sexual harassment, maternity harassment* and power harassment**. We shall not permit any harassment.
*maternity harassment: harassment related to pregnancy, childbirth, childcare leave
**power harassment: abuse of authority in the workplace, including mental abuse through oppressive remark and denial of human dignity
(2) Safe and healthy work environment
Carlit Group shall make efforts to maintain and improve safe and healthy work environment for officers and employees so that everyone works with security. Carlit Group shall observe all labor laws and shall respect workers’ rights.
Article 4. Appropriate execution of job assignments
- Officers and employees shall follow corporate policies, observe Laws, and shall properly understand and carry out instructions and orders in the course of business.
- Officers and employees shall observe the corporate regulations of administrative authority and shall not carry out their job assignments exceeding the authorized scope.
- Officers and employees shall clearly distinguish the corporate affairs from the personal affairs. Officers and employees shall not bring personal matters into the workplace, and shall not bring corporate matters into the private life.
Article 5. Prohibition against acts in conflict of interest
- Officers and employees shall faithfully carry out business tasks and shall not act or use information against the interests of the company.
- Officers and employees shall not work for our clients or other corporations as their officers or employees, and shall not engage in works for profit without permission of the company.
Article 6. Preservation of corporate assets and Management of information
Officers and employees shall preserve corporate assets and confidential information.
(1) Corporate assets
Officers and employees shall properly manage and use Carlit Group’s tangible and intangible assets only for carrying out assigned jobs, and shall not use them for any other purposes.
(2) Intellectual property
Officers and employees shall protect Carlit Group’s intellectual property, such as industrial property rights, to ensure that such intellectual property rights are not used inappropriately by other companies or other parties. Officers and employees shall respect and shall not infringe on the intellectual property of other companies, same as Carlit Group’s intellectual property.
(3) Confidential Information
Officers and employees shall not leak any confidential information to anyone other than the company concerned, shall not acquire them by illicit means, or shall not use them personally. Even after retirement, officers and employees shall not leak, shall not acquire by illicit means, or shall not personally use the confidential information that officers and employees gathered during the tenure of office, either.
Article 7. Responsibility for customers
Carlit Group shall provide satisfaction to our customers through supplying superior products and services.
(1) High quality, fair price and on-time delivery date
Carlit Group shall consider the delivery of defective products and the failure to meet the promised delivery date as serious problems that lose the company credibility, and shall make every efforts to maintain and improve product quality, and to ensure stable products supply at a fair price.
(2) Protection of confidential information of other companies
Same as Carlit Group’s confidential information, officers and employees shall not leak any confidential information of our customers, clients or business partners to anyone other than the company concerned, shall not acquire them by illicit means, or shall not use them personally. Even after retirement, officers and employees shall not leak, shall not acquire by illicit means, or shall not personally use the information of other companies that officers and employees gathered during the tenure of office, either.
(3) Maintaining sound relationship
Officers and employees shall carry out fair transactions for customers and shall make every efforts to maintain long-term good relationship.
Article 8. Assurance of fair transactions
Carlit Group shall assure all transactions are fair.
(1) Establishment of a fair and transparent business relationship
When selecting business partners and deciding transaction details, officers and employees shall comprehensively consider objective information, such as product quality, service contents, price and past results of transactions, and shall make every efforts to ensure fairness and transparency of transactions and to procure competitive materials and equipment.
(2) Observance of the Antimonopoly Act and competition laws around the world
Officers and employees shall keep fair and free competition and observe Antimonopoly Act of Japan (Act on Prohibition of Private Monopolization and Maintenance of Fair Trade), foreign competition laws and other related laws around the world. Officers and employees shall not negotiate prices or sale destinations with other competitors, and shall not restrict sales price and other terms and conditions of business partners. In addition, we do not directly or indirectly force business partners to accept transaction terms and conditions by using dominant bargaining power.
(3) Observance of the Subcontract Act
In procurement transactions, officers and employees shall observe the Subcontract Act of Japan (Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors) and other related regulations and always ensure fair transactions with subcontractors on an equal footing.
(4) Prohibition of Insider trading
Officers and employees shall not buy or sell shares using undisclosed internal material information, and shall not provide such information to third parties including family members.
Article 9. Relationship with shareholders and investors
Carlit Group shall strive to establish good relationship with shareholders and investors by disclosing information in a timely and appropriate manner.
- (1) Carlit Group properly disclose information on business activities to shareholders and investors.
- (2) Carlit Group shall disclose financial information accurately recorded in accordance with the related laws and the appropriate accounting standards.
Article 10. Contribution to local communities
Carlit Group shall make a contribution to the development of local communities and strive to establish good relationship with them.
Carlit Group closely work and cooperate with local communities and strive to actively contribute to them.
Article 11. Business entertainments, Gifts and Political donations
- Officers and employees shall observe domestic and overseas laws, company regulations and group codes regarding business entertainments, gifts, donations and contributions to civil servants, political parties and government officials, and shall not be involved in bribery act as well as any act deviating from social common sense.
- Officers and employees shall seek to maintain transparent and fair relationship with politics, political parties, administrative office and government agencies, and take appropriate actions in accordance with related laws and regulations in Japan and overseas.
Article 12. Opposing stance against Anti-social forces
- Carlit Group shall take a resolute stance against Anti-social individuals and groups that threaten social order or security. Officers and employees also shall take a resolute stance against such Anti-social forces without fear.
- Carlit Group shall make organizational effort against Anti-social forces intervention seeking support from police and lawyers without isolating each officer and employee.
- Carlit Group shall refuse any transactions with Anti-social forces and shall establish an internal control system to refuse such transactions.
- "Anti-social forces" in this charter means individuals or groups as indicated below.
- "Boryokudan" (crime groups) and "boryokudan" affiliated organiztions as prescribed in the "article 2 (ii) of the Act on Prevention of Unjust Acts by Members of Organized Crime Groups"
- Members of organized crime groups and their affiliated organizations as prescribed in the preceding paragraph
- Groups or individuals of "sokaiya" racketeer groups, groups engaging in criminal activities under the pretext of conducting social campaigns or political activities and crime groups specialized in intellectual crimes
- Besides the individuals or groups prescribed in each preceding paragraphs, groups or individuals that make unreasonable demands and pursue unjust economic profits by the use of violence, threats, menacing language and fraud
- Groups or individuals that make unjust demands and pursue economic profits through mentioning the connection with one of the groups, members or individuals prescribed in the preceding paragraphs.
Article 13. Efforts to environmental issues
Carlit Group recognizes the importance of environmental issues and shall observe laws and regulations relating to the global environment. Carlit Group shall strive to reduce environmental burden through working actively on the following items and shall aim for a friendly corporation to global environment.
- (1) economical use of resources
- (2) recycle of resources
- (3) energy conservation
- (4) reduction of waste from manufacturing process
- (5) others relating to reduction of environmental burden