Compliance

The Group strives to enhance and strengthen its corporate governance to realize transparent, fair, agile and definitive decision-making to live up to the trust of its shareholders and other stakeholders as well as to achieve sustainable growth and enhancement of its corporate value over the medium- to long-term. Please refer to the details below.

The executive officers and employees of the Group are required to act with integrity based on the ethics and values appropriate for business persons as members of the society. Based on the recognition, the Group has established “Compliance Program” as a specific code of conduct applicable to the executive officers and employees of the Group with the code of conduct to realize a fair and proper management and harmonize with civil society through strict adherence to social norms, ethics and regulations. In order to ensure full and strict compliance, the Company who is an operating holding company classifies business segments and others (hereafter referred to as “business classification”), and the Head of Corporate Division shall oversee the initiatives on compliance in a cross-segmental manner. Besides, the persons in charge in Corporate Division shall provide compliance education and awareness building to the executive officers and employees of the Group. The Board of Directors shall oversee the Group by the business classification, and the Corporate Division supervises and grasps overall situation of compliance in the Group by the business classification. Both Directors of the Board and the Corporate Division periodically report such status and activities to the Board of Directors and Audit and Supervisory Committee.

The Group has established a reportng system that any directors, officers, and employees of the Group, or any persons who have been engaged in their duties up to one year prior to the time of its reporting could report any misconduct, violation of laws, Articles of Incorporation and internal regulations, or suspected misconduct/violation (hereafter, collectively referred to as the “Fraudulent Practices”) directly to Management Office of the Risk Management Committee served as internal contact point or the law firm served as external contact point. Furthermore, the Group shall ensure that the reports shall be kept confidential and protected, and the persons who report the Fraudulent Practices shall be protected and will not suffer any disadvantage.

The Group complies with anti-corruption laws and regulations in each country and region in which it operates, and is committed to conducting its business operations with integrity and fairness. As a company responsible for critical social infrastructure, including payment services, we do not tolerate any form of corruption, including bribery, kickbacks, or conflicts of interest, and we are committed to maintaining and enhancing public trust.We set forth this basic policy in internal regulations such as the Compliance Program and require all officers and employees to comply with it.

Key Initiatives

・ Prohibition of Corrupt Practices

We prohibit bribery of public officials, improper provision of benefits to business partners, receipt of rebates from suppliers, maintenance of off-book funds, and similar practices.
We prohibit corrupt practices conducted through third parties such as agents, intermediaries, and subcontractors, whether direct or indirect. We avoid any conduct that creates the appearance of impropriety in our dealings with political and governmental entities. We follow all prescribed reporting and approval procedures when necessary.

・ Managing Conflicts of Interest

We do not engage in any conduct that conflicts, or may potentially conflict, with the interests of the company.If a potential conflict of interest arises, we report it to a supervisor and take appropriate action.

・ Appropriate Gift-Giving and Entertainment

We conduct all gift-giving and entertainment involving business partners within socially acceptable limits. In cases of doubt, we seek prior consultation with the Corporate Division and take appropriate action under its guidance.

・ Whistleblower System

We establish internal and external reporting channels to enable the early detection and correction of misconduct.We accept anonymous reports and strictly prohibit any adverse treatment of whistleblowers on the grounds of having made a report.
In the event that a whistleblower is subjected to adverse treatment, we take prompt relief and remedial measures in accordance with internal regulations.

・ Education and Awareness

We provide regular anti-corruption training to officers and employees and ensure thorough awareness and understanding of relevant regulations, including the Compliance Program.

・ Audit and Monitoring

We audit and verify compliance with relevant regulations, including the Compliance Program, and report to senior management and the Board of Directors as necessary. In addition, the Risk Management Committee regularly evaluates and reviews the operation of the whistleblower system.

・ Response to Violations

When we identify violations, we implement corrective and preventive measures and take disciplinary action against those involved in accordance with employment regulations and other applicable rules.We reserve the right to pursue legal liability where appropriate.