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Compliance Enhancement

(1) Establishment of rules of conduct for the POLA ORBIS Group

In February 2017, the POLA ORBIS Group established the POLA ORBIS Group Code of Conduct, which prescribes the rules of conduct for practicing the new Group philosophy in "I. Actions to Sensitizing the World to Beauty" and such rules for self-control with a sense of international social ethics as a global corporate group, in addition to such rules for observing laws, regulations and in-house rules in "II. Actions to Grow as Individuals and Group."

(2) Risk management enhancement

Establishment of priority risks for the Group and risks for the respective Group companies, and initiatives for reducing those risks

A meeting of CSR secretariat managers at the respective Group companies

A meeting of CSR secretariat managers at the respective Group companies

The POLA ORBIS Group is analyzing the priority risks it should address and undertaking improvement activities for reducing those risks.
In concrete terms, the POLA ORBIS Group identified risks through discussions that the Group CSR Committee chairman had with the managers of the respective departments and corporate auditors, and established the order of priority for the identified risks based on the degrees of their impact on operations and the frequencies of their occurrence. The POLA ORBIS Group then set issues such as overseas business strategies and the sophistication of the IT infrastructure as problems the Group should address in 2017 following their discussions at Group strategy meetings.
Moreover, the Group CSR Committee approved risk management plans developed by the respective Group companies and reported them to Group strategy meetings following resolutions on them that were adopted at their respective executive meetings. The respective Group companies are taking the initiative for reducing risks. The Group CSR Committee is monitoring their progress periodically. The Group CSR Committee will submit timely reports to Group strategy meetings according to the progress and conditions in cases where risks surface unexpectedly by the end of this year to consider countermeasures.

Establishment and management of internal control for running organizations soundly and efficiently

The POLA ORBIS Group set Basic Internal Control System Policies according to an approach adopted in the Companies Act in order to build the risk management system needed for ascertaining various risks in business activities and dealing with them appropriately, keep this system in good condition and apply it. The POLA ORBIS Group is promoting public awareness by means including the use of an intranet so that all employees can understand the Policies sufficiently.
Regarding the internal control report system (J-SOX) required in the Financial Instruments and Exchange Act that took effect in 2006, the respective Group companies are self-inspecting the state of work process establishment and application (control self-assessment). The Internal Audit Division is monitoring and dealing with the inspection results. Group companies are respectively promoting understanding of internal control related to financial reports through internal self-inspections.

Internal audit execution

Internal audits in the POLA ORBIS Group are aligned with audits by corporate auditors and audits by audit corporations. Internal audits are playing their part in the governance of the POLA ORBIS Group as one of the so-called three-way audits.
In concrete terms, internationally-licensed full-time members of the Internal Audit Division established at POLA ORBIS HOLDINGS INC. are conducting internal audits from an independent and objective standpoint. The key audit themes are (1) compliance (whether or not corporate activities are undertaken in compliance with laws, regulations, rules and social norms), (2) governance (whether or not a governance structure has been built and is working effectively at the respective Group companies) and (3) the reliability of financial reports (whether or not corporate activities are undertaken in a way that is able to deliver financial information accurately and speedily to society, particularly investors). The Internal Audit Division is evaluating the respective Group companies and their respective departments through field audits that place emphasis on these three points and offering them advice for improvement. The respective Group companies are addressing the audit findings in an attempt to improve the governance of the POLA ORBIS Group as a whole.

Execution of Group-wide training through the formulation of a business continuity plan (BCP)

BCP training

BCP training

The POLA ORBIS Group formulated a business continuity plan (BCP) in connection with initial responses by the respective Group companies based on its experience at the time of the Great East Japan Earthquake in 2011. The POLA ORBIS Group is providing training to verify the effectiveness of its BCP every year.
In 2016, the POLA ORBIS Group provided initial response training (safety confirmation for all Group employees, the launch of BCP response headquarters and responses under conditions that cause employees to be stranded), gave Group employees opportunities to actually experience the initial responses, and dealt with problems that were identified through the training.
At the same time, the POLA ORBIS Group provided training for verifying provisional response plans (the identification of prioritized recovery operations and execution plans for them). The Group is preparing an organization that makes early operational restoration possible in this way.
POLA ORBIS Group offices maintaining overseas bases began formulating their BCPs in 2015 as well. Those offices are confirming the safety of office facilities and providing initial response training, such as safety confirmation. They are each aiming to formulate a BCP whose level equals that of the same plan at Group companies in Japan in the future.

Personal information management

Measures for addressing compliance violations stated in the Compliance Book

Measures for addressing compliance violations stated in the Compliance Book

PCIDSS Certification Mark

PCIDSS Certification Mark

The POLA ORBIS Group is managing personal information with particular caution because the Group receives such information directly from customers in many cases due to the sales methods it adopts, including direct selling. The respective Group companies are promoting cautious personal information management based on the Privacy Policy, the Information Security Policy and other policies established by the POLA ORBIS Group.
Officers in charge of information security measures appointed at the respective Group companies are making a Group-wide inventory of personal information twice each year (in May and November). To make the management of personal information by external contractors exhaustive, the POLA ORBIS Group also required the officers in charge to investigate the contractors and conduct audits of the contractors once each year or more frequently in 2014.
The Group also changed the in-house rules to give the widest possible publicity to the Social Security and Tax Number System that commenced in 2016 and the Revised Act on the Protection of Personal Information Held by Administrative Organs that was enforced in 2017.
Moreover, the Group is stepping up information management across the board by requiring suppliers to manage their contractors. POLA INC. acquired certification under an information security framework called the Payment Card Industry Data Security Standard (PCIDSS) for its electronic commerce site. In the meantime, ORBIS Inc. gained certification under the PrivacyMark System.

Education and enlightenment related to information management

The POLA ORBIS Group states matters related to information security in the POLA ORBIS Group Code of Conduct in order to manage information thoroughly. The POLA ORBIS Group is instructing all Group officers and employees to read out and collate documents when making an inventory of personal information.
Furthermore, the POLA ORBIS Group set the Social Media Policy and Guidelines to prevent Group employees from causing problems through social media. The Group is seeking to promote understanding and enlighten its employees through initiatives such as in-house e-learning programs and lecture meetings. In particular, the Group is providing training on how to use social media to a wider scope of individuals, including store employees, fresh recruits and successful applicants.

Confrontation with antisocial groups

The POLA ORBIS Group is taking the initiatives stated below in order to cut off and remove its relationships with antisocial forces to achieve a higher goal of guaranteeing the appropriateness and soundness of its operations. The POLA ORBIS Group declares "confrontation with antisocial groups" in the POLA ORBIS Group Code of Conduct.
Furthermore, the POLA ORBIS Group created the rule of adding a clause on the removal of antisocial groups to contracts known to all Group companies.


  1. A written pledge to observe the POLA ORBIS Group Code of Conduct submitted by all Group employees
  2. Cooperation with police and other specialized external agencies
  3. Introduction of a clause on the removal of antisocial forces to contracts, etc.
  4. Advance screenings for preventing transactions with antisocial groups
  5. Consolidation of information about antisocial groups
  6. Statement of "firm responses to antisocial groups" in the POLA ORBIS Group Code of Conduct, which is distributed to all Group employees to enlighten them and promote understanding

(3) Promotion of Understanding of Compliance

Provision of lecture meetings and e-learning programs for all officers and employees

A Group CSR lecture meeting

A Group CSR lecture meeting

The POLA ORBIS Group is seeking to promote understanding of compliance among all Group officers and employees in order to prevent compliance violations.
The POLA ORBIS Group sets themes for all Group officers and employees, such as information security, insider trading and points to note regarding social networking services, and offers lecture meetings on the selected themes every year. The POLA ORBIS Group ensures that all Group employees understand the themes by showing the videos of the lecture meetings on subsequent dates to employees who were not able to attend the meetings.
The POLA ORBIS Group linked the details of the e-learning programs it offered in 2017 with specific actions by including compliance-related themes, such as proper accounting, the Consumer Contract Act, information security, insider trading, gift-giving and entertainment restrictions, harassment and whistle-blowing systems. The Group distributed the Collection of CSR Points, an e-learning program summary, to employees with no Internet access to promote their awareness.

(4) Monitoring Enforcement

Identification of problems through awareness surveys of employees and their improvement

A briefing session on an awareness survey of employees

A briefing session on an awareness survey of employees

The POLA ORBIS Group is conducting awareness surveys of Group employees to confirm the current state of their job satisfaction and compliance and to discover problems with the state and a course for their improvement in order to achieve the greater objectives of sustaining development permanently and maintaining and enhancing the Group value stated in the Group philosophy.
Based on the survey findings, the respective POLA ORBIS Group companies are setting themes such as harassment improvement, overtime reduction, operational efficiency improvement and paid leave promotion for achieving work-life balance, along with a sense of growth improvement and career development support enhancement, formulating action plans for improvement, and working on improving the themes. The Group began the same surveys at Group companies overseas in 2016. Those companies are formulating action plans in the same manner as their counterparts in Japan.

Whistle-blowing system (helpline)

The POLA ORBIS Group has developed a system that enables all Group officers and employees to submit reports and seek advice. The POLA ORBIS Group is ascertaining internal risk information directly through the system and linking this information with risk-related proposals and the prevention of violations. External subcontractors receive reports from Group officers and employees, anonymize their reports, and report only their content to the Group CSR Committee office. They accept reports via e-mail or postal mail around the clock and all year round. The Group CSR Committee office conducts investigations in the departments concerned of the respective Group companies. The Group CSR Committee office issues instructions for improvement in cases where the investigations have found points for improvement. The office reports the state of helpline use to the corporate auditors every month. The office reports the state periodically to the Board of Directors as well. In the structure of the helpline, the anonymity of whistle-blowers is protected under in-house rules, laws, regulations and the like. Whistle-blowers are not treated disadvantageously. The respective POLA ORBIS Group companies make a correction in accordance with their in-house rules in the event of retaliation against a whistle-blower due to report submission. Group companies and offices overseas introduced a helpline similar to this service used by their counterparts in Japan as well. They have an established system for whistle-blowing in the local languages. The POLA ORBIS Group is measuring the degree of recognition through compliance awareness surveys of employees and by proactively making announcements through means including posters put up in offices where the degree of recognition is found to be low, in addition to distributing a pamphlet explaining how to use the helpline to all Group employees to promote their understanding.

Helpline structuren
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