Compliance

The directors and employees of the Group utilize the DOWA Group Corporate Mission, Vision, Values, and Code of Conduct to guide them in their day-to-day business activities. In addition, our continued efforts to spread awareness of our whistleblower system, combined with the implementation of internal audits, helps with the prevention and early detection of any fraud or misconduct in the Company or at Group companies, and accordingly we take appropriate measures whenever the need should arise. We will establish and operate a framework governing our business activities with high ethical standards and aim to be an open and transparent organisation. We also prevent corruption, bribery, abuse of a superior position and other unfair and illegal acts, and we do not treat whistleblowers in relation to such acts in a prejudicial manner.

Centered on the General Affairs & Legal Department, which is the department in charge of compliance, DOWA Holdings has stipulated items for regulations that comprise a system of major company regulations. These include regulations for the Board of Directors, administrative authority, accounting, document handling, purchasing, and information system management. This system of regulations serves to standardize regulations across the Group and clarify the responsibilities, authority, and authorization procedures of each position. In addition, the Internal Audit Department conducts internal audits, including regular monitoring and risk assessment.

The Group clearly states inside and outside the Company that it will prevent corruption, bribery, abuse of a dominant bargaining position, and other unfair and illegal acts. It will not treat whistleblowers who report such acts unfavorably and will not have any relationship with anti-social forces.
We will also ensure transparency in relation to deposits and withdrawals and work to prevent embezzlement and money laundering. We will not use such corrupt practices as bribery and bid-rigging as a business practice, and we will demand that our business partners and others also prevent corruption. In addition, we ensure that all officers and employees comply with our standards and related laws or regulations and monitor compliance status through internal audits.

We position sustainability as a core element of our management and are in the process of developing policies related to Environmental, Social, and Governance (ESG) practices.
In recent years, from the perspective of supply chain management, there has been an increase in requests from business partners to disclose the status of their corruption prevention measures before and during transactions. In response to this trend, in order to increase transparency in transactions and build trust with customers, we have formulated a new Anti-Corruption Policy in fiscal 2023 while ensuring the consistency of our Code.

The Group uses risk management plans to identify and assess the business risks surrounding itself with regard to anti-corruption, including bribery, and select key risks. Based on these plans, the Group is strengthening and enhancing its risk management flow, which consists of a series of countermeasures, reviews and audits.
These priority risks are shared with the Sustainability Subcommittee, which reports on the risks of high importance to the Sustainability Committee. Those risks are discussed by the Sustainability Committee, and key risks related to management risks are reported to the Board of Directors for oversight. The Board of Directors shares issues related to risk management and discusses how to resolve them.
The General Affairs & Legal Department, the supervising department at the center of our organized response to anti-social forces, collaborates with outside specialists such as lawyers as necessary. 

In order to ensure compliance, all employees must have a correct understanding of corporate ethics, various laws and regulations and company rules. The company continuously implements compliance education activities for all employees.
The Group operates the Compliance Café, a website on the intranet that provides information on compliance, including case studies and videos of lawyers explaining relevant laws and regulations, which can be viewed by employees within the Group. In addition, the Compliance E-Mail Magazine, which focuses on case studies and examples of compliance violations, is distributed monthly to all employees in the Group.
We are working to raise employee awareness of compliance and prevent compliance violations by expanding and enhancing various types of compliance-related education.

The Company has established the DOWA Consultation Desk, which allows any Group director or employee to anonymously report and consult with outside lawyers regarding harassment, fraud including anti-corruption etc., or any other improper activity. Confidentiality concerning reports made and the protection of reporting parties against unfair treatment are both guaranteed by the DOWA Consultation Desk. Our internal reporting system is also available to all of our stakeholders, including employees of suppliers and cooperating companies. Consultations and opinions expressed are kept confidential and are addressed promptly and appropriately. For reports of possible compliance violations received at the desk, the facts are investigated and a final determination is made as to whether or not a violation has occurred. If the investigation reveals that a compliance violation has occurred, the Company takes necessary corrective measures and measures to prevent recurrence.

The Company has established the Rules for Harassment Prevention, a series of rules that all employees must follow in order to prevent different types of harassment. We also believe it is important to prevent the occurrence of such incidents and respond to them if they do occur. To this end, we conduct harassment training for managers throughout the Group. In addition, we strive to prevent workplace harassment by putting up posters in our offices and disseminating information through the Company intranet.