Compliance

Basic Policy

Our group not only complies with laws and regulations, but also respects social norms and supports and respects international norms in order to realize a sustainable society. We will conduct our corporate activities with high ethical standards, good sense, and responsibility in accordance with the Tanseisha Group Code of Conduct, which is to be adopted by all officers and employees of Tanseisha Group companies.

The Tanseisha Group Code of Conduct is regularly and appropriately reviewed by the Sustainability Committee to ensure its effectiveness in response to changing social demands. A system has been established to submit and report to the Board Director any important sustainability policies or revisions considered by the Sustainability Committee. Most recently, in February 2025, these standards were revised with the aim of sustainably improving corporate value and addressing ethical requirements.

Compliance Promotion System

Based on the "Basic Compliance Regulations," the Tanseisha Group implements its group-wide compliance program under the ultimate authority and responsibility of the Representative Director, with Director in charge of the Management Department serving as the management supervisor.
We have established a Risk and Compliance Committee to oversee and promote risk management and compliance activities across our entire group. Its purposes include formulating a "Risk and Compliance Policy" and compliance education plan, consolidating risk management information implemented by each department and evaluating the effectiveness of measures, and determining response policies for serious incidents. The committee consists of 14 members in total, including President and Chief Executive Officer, five Director (including one full-time Audit and Supervisory Committee Member), and nine senior executives, and it meets, in principle, once a month.
Furthermore, based on the "Internal Audit Regulations," an independent internal audit is conducted once a year. This audit includes the performance of business activities, including compliance with the "Tanseisha Group Code of Conduct" and "Basic Compliance Regulations," as well as an evaluation of the development and operation of internal controls related to financial reporting. The audit investigates all aspects of business activities, aiming to improve the efficiency of business operations and contribute to improvements in business procedures, the appropriateness of accounting treatment, and the preservation of assets.
In addition to compliance training, we conduct surveys on the implementation status of the "Tanseisha Group Code of Conduct" for all employees, and we continuously implement necessary improvements based on the results.

Anti-corruption efforts

The Tanseisha Group Code of Conduct stipulates "fair business practices," and in order to ensure fair and free competition between companies, proper transactions, and responsible procurement, we strive to ensure thorough compliance by maintaining healthy relationships with politics and government, and prohibiting all forms of corrupt practices that are considered legally and socially unjust, such as bribery, conflicts of interest, fraud, and money laundering.We have also signed the United Nations Global Compact and support one of its ten principles, "Prevention of corruption in all its forms, including extortion and bribery."

Our group places the results of risk assessments regarding corruption and the implementation status of preventative measures under the management of the "Risk and Compliance Committee." This committee comprehensively shares the status of these efforts with the Board Director, and strives to build highly transparent governance under appropriate supervision by management. In the event that a significant concern arises, a system is in place to report and submit it to the Board Director on an individual basis.
(*For details on the risk management system, including the assessment of corruption risk, see "Risk Management Please see the "Risk Management System" section on the page.

As part of our anti-corruption efforts, we provide compliance training to all employees of Group companies, which includes the prohibition of all forms of corrupt practices. We also strive to protect whistleblowers by ensuring that their confidentiality is maintained and that they are not disadvantaged for reporting corrupt practices or other wrongdoing. We have established and are operating an internal reporting system in accordance with legal requirements.

Anti-corruption efforts in purchasing and procurement activities

Our company implements qualification checks and contract management based on our "Purchasing Regulations" not only within our own organization but also in our procurement activities with our business partners (third parties such as cooperating companies), in order to prevent corrupt practices and promote fair transactions.

① Pre-screening of partner companies and collection of diverse data.
When placing orders for services, we prioritize "continuous business partners" who have undergone prior screening and signed a basic agreement. For continuous business relationships, our screening department utilizes databases from external expert organizations to conduct a comprehensive investigation and evaluation of basic information such as location and representative, financial status, and legal qualifications, as well as compliance risks and corruption risks such as past legal violations, administrative penalties, scandals, and involvement with anti-social forces. After registration, we conclude a basic agreement and manage these partners. Even in the case of "one-off transactions" where a basic agreement is not concluded, prior screening and approval procedures based on the regulations on job authority are mandatory, and transactions with unscreened businesses are prohibited.

② Compliance obligations and ongoing management under the basic agreement
The basic agreements concluded with our ongoing business partners include compliance clauses (such as sustainable procurement guidelines) that include "severing all ties with anti-social forces" and "preventing corrupt practices (bribery, extortion, embezzlement, etc.)," legally obligating them to comply with laws and regulations and maintain high ethical standards. Furthermore, we maintain up-to-date information through regular inspections even after registration, and we have a system in place to take measures such as deregistering or suspending transactions if risk information such as misconduct or legal violations is discovered.

Compliance training

In recognition of the importance of compliance, the Tanseisha Group conducts compliance training via e-learning once a year for all officers and employees of the Group, with the aim of sharing and establishing information such as the basics of compliance, the Group's Code of Conduct and related regulations including the perspective of risk management, information on cases of fraud and scandals, and the internal reporting system.In addition to training for managers, compliance seminars are also held for part-time officers of Group companies (managerial employees at the head office) to raise awareness of compliance.