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Compliance Initiatives

POLA ORBIS Group Compliance Policy

The POLA ORBIS Group considers compliance to be events and actions that cannot be accepted based on laws concerning business, articles of association, various internal regulations, our Code of Conduct, and corporate ethics, and we work to prevent compliance infractions and the reoccurrence of such infractions.

POLA ORBIS Group Code of Conduct

The POLA ORBIS Group revised the POLA ORBIS Group Code of Conduct in April 2021, reflecting changes to social circumstances and updates to the Group's medium-term management plan. In addition to the original rules of conduct for practicing the new Group philosophy (I. Actions to Sensitizing the World to Beauty) and rules for compliance with laws and internal regulations (II. Actions to Grow as Individuals and Group), we have also established the POLA ORBIS Group Code of Conduct, which provides rules of conduct for strict self-control with a sense of international social ethics, as members of a global corporate group. This Code of Conduct is made known to all Group employee, both in Japan and overseas, with support for all necessary languages. In order to promote deeper understanding of the Code of Conduct, we provide e-learning training for all Group employees both in Japan and overseas to learn about the Code of Conduct on an annual basis.
The POLA ORBIS Group Code of Conduct is also updated once every 3–4 years, based on a review of the implementation of the Group philosophy and moral values, in order to assess its effectiveness.

Compliance System

The Group CSR Committee was established within the POLA ORBIS Group to expand and develop CSR activities (compliance, etc.) to the entire Group. The Group CSR Committee is headed by the POLA ORBIS HOLDINGS' CSR Head Director based on the POLA ORBIS Group's Group CSR Committee regulations, and is made up of directors from each Group company who join the Committee as CSR Promotion Officers. When necessary, Workplace Coordinators are appointed within each Group company, investigating and solving CSR problems. Additionally, the Committee is involved in education through holding lectures, e-learning courses, etc., so that employees can understand and be educated about CSR.

Compliance Training

The POLA ORBIS Group strives for understanding and pervasion of compliance for all directors and employees in order to prevent compliance infractions.

CSR Lectures

Target: All Group Directors and Employees (100% completion rate)
Term: Annual
Theme: Learning Focused on Key Themes
2017: The POLA ORBIS Group Code of Conduct
2018: Human Rights
2019: Working Style Reforms
In 2020 we conducted harassment training for managers, with 100% of target personnel participating.

CSR E-Learning

Target: All Group Directors and Employees
Term: Annual
Theme: Comprehensive Learning about Compliance and Sustainability
2020 e-learning content
Group philosophy, SDGs, human rights, environment, preventing infectious diseases, points for attention when working from home, accounting fraud, personal information, information security, transactions, legal risks, harassment, insider trading, gifts and hospitality / entertainment, internal reporting systems / whistleblowing (helpline), health management, long working hours, Article 36 agreements, mental health

Discovery and Response to Compliance Violations

Compliance Survey

The POLA ORBIS Group conducts annual compliance surveys of all Group executives and employees with guaranteed anonymity. In addition to a comprehensive check of compliance-related items, employees are also asked to provide free answers on events that you think constitute compliance violations (including human rights and environmental issues). The response rate for the surveys is over 90%, and they comprehensively identify compliance risks and other risks.
The results of the responses are promptly reported to the Board of Directors. All matters raised as issues in the responses are resolved by the responsible directors and auditors, and reported to the Chief CSR Officer (Director of POLA ORBIS Holdings).

Internal Reporting System (POLA ORBIS Group Helpline) and Business Partner Hotline

The POLA ORBIS Group has established an internal reporting system (the POLA ORBIS Group Helpline) to anonymously receive reports regarding compliance violations (including Code of Conduct violations and human rights issues). The facts surrounding internal reports by whistleblowers are investigated and verified using third-party organizations, and reported to the Board of Directors for resolution.
The Group has also established a Business Partner Hotline to receive reports on compliance violations (including Code of Conduct violations and human rights issues) from business partners. The Business Partner Hotline accepts complaints not only from business partners but also from all manner of other stakeholders. If it is found that the content of the report is an event that may have a socially negative impact, such as where the behavior of employees or the Group's corporate activities run contrary to the Code of Conduct, we follow an established process working promptly with the responsible department(s) to take action to resolve the issue.

ESG Information
Corporate Report2020
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