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Compliance, Anti-Corruption
Compliance Policy
All executives and employees of POC Group shall comply with laws and regulations in conducting business activities, respect social norms and ethics, and always act with integrity. In particular, in construction bidding, we shall comply with the Antimonopoly Law and other related laws and regulations, and practice fair and free competition.
The Code of Conduct of POC Group includes “anti-bribery and anti-corruption” clauses, which stipulate “development of sound and normal relationships by complying to local laws and regulations” and “non-involvement in any form of act that may constitute corruption including bribery” when working with local third parties including politicians and government officials. We also ensure thorough dissemination of these policies both internally and externally.
Compliance Promotion Structure
We established Compliance Policy to ensure the proper execution of our business activities and fulfillment of our social responsibilities.
Compliance Promotion Initiatives
Action Guidelines for Proper Bidding
On March 31, 2009, we issued a "Declaration of Bid Rigging and Declaration of Compliance." As one of the measures to ensure the implementation of the declaration, we established the "Action Guidelines for Proper Bidding" for all executives and employees of POC Group in June of the same year. This guideline is based on the following principles, in light of the Antimonopoly Law and other related laws and regulations:
- Indicating the types of conduct that are prohibited in the course of bidding operations
- Penalties and illegal acts that may be imposed on individual employees in the event of a violation
- Providing specific measures to be taken by executives and employees when they come in contact with suspicious behaviors
The guideline clearly states the Group's basic stance against illegal activities: "Not to do, not to allow, and not to overlook. We provide all officers and employees of the Group with the guideline via the intranet. In addition, compliance training on the guideline is conducted every year to ensure the understanding.
Our Response to Illegal Acts in Public Project Bidding
In the "Action Guidelines for Proper Bidding," POC Group clearly stipulates that "the Company will never allow anyone, for any reason, to act in violation of the Anti-Monopoly Law, or the crime of obstruction of public contract-related auctions, etc., or other laws and regulations," and that officers and employees who commit violation of the law shall face serious consequences including disciplinary actions, after appropriate procedures are taken.
Whistleblower System
As part of measures to further promote thorough compliance, Penta-Ocean Construction Group established an outside office for consulting a lawyer, the Compliance Consultation Desk, apart from an internal contact point. Employees can report incidents that may conflict with laws, regulations, corporate ethics, and internal regulations, or a suspected violation of compliance. The consultation desk is available not only to officers and employees of POC Group, but also to all people affected by the Group’s corporate activities. Anonymous reports are also accepted, and it is clearly stated that whistleblowers shall be protected from any adverse treatment based on the Whistleblower Protection Act.
The contact point for whistleblowers is posted on the Company's intranet and website, and can be found at branch offices and construction offices, and is also announced during compliance training. Additionally, we have established the Harassment Consultation Desk and the Human Rights Consultation Desk to receive consultations on various types of harassment such as sexual harassment, power harassment, and maternity harassment, as well as general human rights issues.
For received consultations, the Risk Management Committee investigates each case and takes appropriate actions, such as coaching and discipline instructions, in accordance with company regulations.
Compliance Training
POC Group provides various compliance training sessions, including anti-corruption training, for all executives and employees.
In FY3/24 in Japan, in addition to the "Declaration of Bid Rigging and Declaration of Compliance" based on past scandals, we also conducted training focused on compliance with laws and regulations such as the Construction Industry Act and the Industrial Safety and Health Act. All domestic POC Group executives and employees received the training.
At the same time, in all countries where we operate, we provided training focused on human rights, anti-bribery and prevention of unfair competition etc., and all executives and employees in our overseas offices, including non-Japanese employees, received the training.
Further, in addition to rank-based training on legal knowledge such as the Antimonopoly Act and risk management tailored for young employees, we conducted discussion-based training on case studies of possible internal and external misconducts, tailored for all employees in management positions.
Anti-bribery Training
The Code of Conduct of POC Group includes “anti-bribery and anti-corruption” clause, which stipulates the prohibition of any acts that may constitute corrupt conduct including bribery. We communicate the Code of Conduct through grade-specific compliance training programs to ensure its understanding by all officers and employees. In particular, with regard to bidding for public projects, we provide more far-reaching training on bribery and the National Public Service Ethics Law to executive officers and employees at the managerial level and above. The training is based on actual cases, to ensure that they do not engage in illegal activities. We also provide training on anti-bribery laws and regulations to non-Japanese employees overseas, including case studies, in order to reduce compliance risks.
Thorough Elimination of Anti-social Forces
The Risk Management Committee established a framework that completely eliminates relationships with organized crime groups and other anti-social forces. It also manages and coordinates risks on this front, and has a system in place that enables the immediate response to the emergence of these risks. Furthermore, we carry out various initiatives that encompass our Group's overall business activities, such as providing a wide range of compliance training for POC Group executives and employees, etc. Regarding relationships with our business partners, our contracts (sales of goods contracts, construction subcontracting agreements, etc.) stipulate provisions for the eradication of anti-social forces.
