Compliance

Policies and Stances

In order to meet the expectations of all stakeholders and remain a company that is trusted by society, Gakken Group has established Gakken Group Charter of Corporate Conduct, which proclaims compliance with laws, regulations, and social ethics in its corporate activities and promotes compliance management.
To this end, we have established Gakken Compliance Code, which serves as the standard for the entire Gakken Group. Gakken Compliance Code is designed to provide a clear understanding of the laws, regulations and social ethics that must be followed in implementing Gakken Group Charter of Corporate conduct, with regulations established for each stakeholder. In addition, we have established a Compliance Hotline as a point of contact for consultation and reporting on compliance issues, which is separate from the normal report line.

System and Mechanisms

Establishment of Compliance Subcommittee

In order to establish and promote compliance within Gakken Group, the Compliance subcommittee has been established under the Internal Controls committee to deliberate on important matters to ensure that corporate conduct is in compliance with laws and regulations. The Compliance subcommittee has also established a harassment task force to deal with human rights violations and various harassment cases.

Deliberation Items

① Matters related to the dissemination and thoroughness of the Gakken Compliance Code.
② Matters related to the enactment, revision or abolition of laws and regulations, corporate conduct based on changes in the social environment, and the review of Gakken Compliance Code.
③ Matters related to the operation of the hotline for reporting compliance violations.
④ Matters related to actions to be taken in the event of noncompliance.
⑤ Matters related to the compliance operation system (the officer in charge and those in charge at each group company).
⑥ Matters related to the implementation of monitoring regarding the dissemination and thoroughness of compliance.
⑦ Other important compliance-related matters.

Composition and Meetings

The Compliance subcommittee is composed of the subcommittee chairman, a few members, and the secretariat. The subcommittee chairman presides over the Compliance subcommittee and the officer in charge of compliance is appointed. Members and the secretariat are nominated by the chairman. Regular meetings are held once a quarter, and extraordinary meetings are held as needed.

Operation of Whistleblowing System

The Compliance Hotline is a single point of contact for all Group employees, and in addition to the internal whistleblowing hotline, lawyers independent from the company also serve as contacts. These internal reports can also be received anonymously, and the regulations stipulate that ① the whistleblower will not suffer any disadvantages, ② retaliation is prohibited, ③ the person incharge must pledge not to divulge any secrets, and ④ the person in charge must not be involved in the handling of whistleblowing cases related to themselves. In addition, the fact of whistleblowing and the response to it are reported to Board of Directors, and Governance Advisory Committee gives objective opinions about the matter.

Implementation of Employee Compliance Retention Monitoring

Gakken Group conducts training for all employees on governance, risk and compliance. We also use an e-learning system to conduct a biennial survey on understanding of Gakken Compliance Code. Since 2017, we have also further increased the level of compliance retention by conducting a survey on understanding of Gakken Group Charter of Corporate Conduct at the same time.

Initiatives to Prevent Corruption

"Gakken Group builds fair relationships with all of its business partners and engages in fair and free market competition. Under no circumstances will we engage in cartels, collusion, maintaining resale prices, or any other conduct that would violate antitrust laws, and we will engage in fair and free competition among businesses. In addition, we treat our business partners with common sense and sincerity, and treat them fairly and justly. "

Response to Antisocial Forces

Gakken Group has no relationship with antisocial forces. If we receive an unreasonable demand from antisocial forces, we will take a resolute stance and will not try to solve the problem by offering money or merchandise. We will not use antisocial forces to gain profits for the company or ourselves.