Compliance / Internal reporting system

Compliance Promotion Framework

Compliance Promotion Meeting, Compliance Committee

The Carlit Group holds a "Compliance Promotion Meeting" once a quarter to ascertain the level of compliance at each of our Group companies.
In addition, the "Compliance Committee" meets every six months to discuss important compliance-related matters and measures to strengthen compliance.

Compliance Promotion Officer

One Compliance Promotion Officer is appointed in each company and department, and is responsible for checking the level of compliance within individual departments and fielding questions regarding compliance from employees.

Compliance training

The Legal & Compliance Department conducts annual training at all factories, sales offices, and business sites of each Group company to ensure thorough compliance training for all employees.

Group Priority Initiatives

Carlit Group Priority Initiatives

• Compliance with Antimonopoly Act and prohibition of bid rigging
• Prevention of corrupt practices (bribery, etc.)
• Prevention of harassment and improvement of work environment
• Thorough compliance with business laws (manufacturing, environment, safety, quality)
• Thorough information security

1. Compliance with Antimonopoly Act and prohibition of bid rigging
   • In order to conduct fair and just corporate activities, the Carlit Group has set compliance of the Antimonopoly Act as one of our important codes of conduct. The prohibition of cartels and bid rigging is clearly stipulated in the "Group Antimonopoly Act Compliance Regulations," and all Group companies are informed of and thoroughly enforced by the regulations.
   • The above regulations specify the types of violations including cartels, rules for contact with other companies in the same industry, rules for disciplinary action against violators, and a system for the reduction or exemption of fees.
     Compliance training on the Antimonopoly Act is provided annually to all Group companies.
2. Prevention of corrupt practices (bribery, etc.)
   • All Group companies are informed of the prohibition of excessive business entertainment and the giving and receiving of gifts in Japan and overseas.
   • The "Group Anti-Corruption Regulations" have been established to prohibit bribery, etc., and stipulate that entertainment and gifts to domestic and overseas public officials and excessive entertainment and gifts to private business partners are prohibited, and all Group employees are required to act with the highest ethical standards.
3. Prevention of harassment and improvement of work environment

   

   • Prohibition of harassment is clearly stated in the employment regulations of each Group company, "Group Compliance Charter," and "Group Harassment Prevention Regulations."
   • Compliance training conducted annually at each Group company places a particular focus on harassment.
   • Through the display of compliance awareness posters at each Group site, we are working to improve the work environment by strictly prohibiting bullying and harassment.
4. Thorough compliance with business laws (manufacturing, environment, safety, quality)
   • Our Group recognizes that compliance with laws and regulations pertaining to the manufacturing, environment, safety, quality, etc. of each Group company, or so-called business laws, is an important management issue.
   • Each Group company conducts semiannual inspections of its compliance with regulatory requirements for products, goods, and services, and is working to prevent illegal or fraudulent activities.
     In addition, we ensure that the details of regulations are reviewed whenever they are revised.
5. Thorough information security
   • The Group is working on risk countermeasures to protect our information assets in accordance with "Group Information Management Regulations."
   • We regularly send out information on information security to our employees and conduct various security training programs using e-learning and other means to raise information security awareness.
   • As a countermeasure against information leakage due to cyber attacks, etc., we monitor unauthorized access through the use of firewalls and security software.
     In addition, we have established a "Group Cybersecurity Policy" and "Group Cybersecurity Handling Procedure" to ensure information security within the Group and implement the necessary measures on an ongoing basis.

   Group Cybersecurity Policy

   1. Management will provide leadership and promote security measures
   2. Strive to improve security measures including the supply chain
   3. Communicate appropriately with stakeholders, and disclose information on security measures.

Internal reporting system (compliance consultation desk)

The Carlit Group has established a "Compliance Consultation Desk" within our Legal & Compliance Dept. and at an outside law firm to recognize illegal and unethical acts at an early stage and take necessary measures. The system is available to Carlit Group officers, employees, those who have retired within the past year, and business partners. Reports and consultations received will be investigated to ascertain the facts, and appropriate actions will be taken in accordance with our internal regulations. Additionally, we have set forth in the "Group Internal Reporting Handling Guidelines" to ensure that whistleblowers and consultants will not be subject to disadvantageous treatment.

Number of internal reports (cases)

FY2021	FY2022	FY2023
10	12	14