Approach to Compliance

Compliance extends beyond merely complying with laws and regulations; it is a critical factor that determines a company’s credibility, competitiveness, and sustainability.
We have established the Basic Compliance Regulations and positioned compliance as one of the most important issues in our corporate management. We have also established an organizational structure to effectively manage compliance-related activities. Under this structure, we ensure all the executives and employees^* of the Tsurumi Group fully understand the necessity and importance of compliance, and are promoting initiatives to foster a legal mindset.
Specifically, we have established the Tsurumi Group Code of Conduct, which requires and ensures that each of our executives and employees act with integrity and ethics, complying with all applicable laws and regulations. Furthermore, we implement an annual compliance training program to continually provide training through in-person courses and a learning management system (LMS).

Going forward, we will continue our efforts to promote and enhance compliance awareness. Through these efforts, we will strive to maintain everyone’s trust and enhance our corporate value.*The term “employees” refers to our regular employees, junior employees, non-regular employees, special assignment employees, contract employees, part-time employees, employees on temporary assignment, and dispatched employees.

Governance

Board of Directors

The Board of Directors bears the ultimate responsibility for supervising and approving the identification, management, and mitigation of the important risks relating to sustainability and compliance from the perspective of enhancing our medium- to long-term corporate value and reducing risks. The Board of Directors receives regular reports from the Sustainability Strategy Committee, Compliance Management Committee, and Risk Management Committee. It then deliberates and reviews the effectiveness of policies, priorities, response measures, and management for the important risks and opportunities relating to climate change, nature, human rights, anti-corruption, and other areas. As the officer responsible for executing business relating to sustainability and compliance, the President provides oversight to ensure that the initiatives of the various committees and related divisions are carried out in accordance with the policies of the Board of Directors. The Board of Directors continuously monitors whether these initiatives are appropriately being integrated into business strategies and management decisions.

Compliance Management Committee

We established the Compliance Management Committee to ensure compliance with laws and regulations and ethical conduct within Tsurumi. The purpose of the committee is to deliberate and decide on the compliance promotion structure and key compliance-related matters. Going beyond compliance with laws and regulations, this committee addresses compliance risks that may have a significant impact on our business activities, including anti-corruption risks such as bribery and coercion and human rights violation risks. The committee has established a compliance promotion structure that includes training and has set up mechanisms such as a whistleblowing system. The committee is chaired by the Managing Director Responsible for Overseeing the Administrative Division. The serving chair convenes executives and employees according to the topic at hand. The key matters discussed and determined by this committee, as well as the status of related actions, are reported to the Board of Directors for its oversight.

Sustainability Strategy Committee

We established the Sustainability Strategy Committee to identify and assess short-term and medium- to long-term risks and opportunities relating to the sustainability of our business activities, and then to deliberate on and decide our response policies and priority issues. Referring to external assessments and international guidelines, the committee considers governance issues, including respect for human rights, responsible procurement within the supply chain, and anti-corruption, while focusing primarily on climate change- and nature-related topics.
The committee is chaired by the Managing Director Responsible for Overseeing the Administrative Division. The serving chair convenes executives and employees according to the topic at hand (at least once a year). The key matters identified by this committee and the response policies are periodically (at least once a year) reported to the Board of Directors for its oversight.

Compliance Promotion Structure

Tsurumi Group Code of Conduct

The Tsurumi Group established the Tsurumi Group Code of Conduct in 2006, based on the belief that it is important for all our executives and employees across our group to have a sense of awareness for establishing a compliance structure that encompasses not only legal compliance but also adherence to social norms, such as morality and ethics. Stipulating how each individual should make decisions and act on a daily basis, we aim to maintain an even stronger commitment to observing laws and regulations and higher ethical standards.
We have created versions of the Code of Conduct in multiple languages to ensure its contents are thoroughly known throughout the Tsurumi Group. The entire Tsurumi Group is committed to ensuring thorough compliance with laws and regulations, as well as with social norms.

Establishment of a Whistleblowing Desk

We have established whistleblowing desks both in Japan and overseas. These serve as desks to accept reports and inquiries directly from employees so that we can identify legal violations, internal regulation violations, and other problematic incidents at an early stage, and then solve them through internal self-correction. We are committed to managing these desks by ensuring they are known throughout our group.
These desks accept a wide range of reports and inquiries and strictly ensure confidentiality so that our employees can use them with peace of mind.
Our internal regulations stipulate matters relating to the establishment and operational structure of the whistleblowing desks, as well as the protection of whistleblowers and related parties. We make sure our employees are aware of these whistleblowing desks by putting up posters and providing training on our compliance website.

Domestic Whistleblowing Desk

We have established a whistleblowing desk to accept reports and consultations on compliance and harassment.
Access to the whistleblowing desk is posted on the company portal site and the desk is promoted on posters, so employees know it exists.
Whistleblowers/consulters can freely choose whom to consult with from “internal personnel” and “external lawyers (male and female)” who are independent from management. All cases accepted by the whistleblowing desk will be reported to the Compliance Management Committee.
The Compliance Management Committee, on the premise of protecting confidentiality and preventing detrimental treatment of the whistleblower/consulter, appoints a person in charge of investigation as necessary, and after conducting a factual investigation, deliberates countermeasures and disciplinary measures.
In addition to the promise of the confidentiality of the report/consultation content, prohibition of detrimental treatment of the whistleblower/consulter due to the fact that they have reported to or consulted with the desk is also stipulated in our regulations to protect the whistleblower/consulter.

Overseas Whistleblowing Desk

At our eight major overseas subsidiaries in China, Asia and North America, we have established whistleblowing desks for employees to directly report/consult regarding compliance and harassment issues.
The whistleblowing desk is thoroughly known within the company.
Reports/consultations are handled by each external desk (law or consulting firm), which is independent of management, in the language of each country where our local affiliate is located to protect confidentiality and prevent detrimental treatment of whistleblowers/consulters.
As we expand our business on a global scale, we have a system in place where cases received at the whistleblowing desks are reported to the Company that bears head office functions as necessary, thereby solidifying governance of the Group.

Compliance Training Program

We provide a compliance program with the aim of raising compliance awareness among all the executives and employees of the Tsurumi Group.
The program consists of training sessions for all executives and employees, as well as training sessions for certain divisions and individuals according to their work contents. The former sessions cover various forms of harassment^*, human rights and business, anti-corruption, and whistleblowing, while the latter cover antimonopoly laws, bid-rigging laws, subcontracting laws, and other relevant laws. We formulate the program at the beginning of the fiscal year and subsequently implement it taking into account the external and internal environments.
The performance data on our compliance training is available on the ESG data section of our website.
*Includes power harassment, sexual harassment, pregnancy harassment, sexual orientation and gender identity harassment, and customer harassment.