We established the Kanadevia Group Charter of Ethical Behavior as a guideline for compliance practices by all Group officers and employees. Every year, we distribute pocket-sized cards to all officers and employees of the Group, including outside of Japan. Officers and employees are encouraged to carry this card with them at all times or check it on the website to help them confirm their own behavior and ensure that they act in a sensible and responsible manner in line with our corporate ethics.

Established as a Group-wide organization to promote compliance management, the Compliance Committee implements various measures to encourage adherence to and raise awareness of laws, regulations, and corporate ethics. It is chaired by the president and comprised of general managers, business site heads, headquarters management department heads, and outside attorneys. The Committee meets once a year to report on activities during the year and discuss and decide on items such as future activity plans. The state of Compliance Committee activities is reported to and supervised by the Board of Directors.

We have established the Marketing Compliance Committee as an organization that provides guidance and supervision to comply with laws, regulations, and corporate ethics in marketing activities and to promote appropriate order-taking activities. By conducting monthly monitoring of marketing departments (checks of physical items related to estimates, bids, and orders; interviews of department heads and the department responsible for creating the estimate, etc.), the Committee verifies whether there were improper or illegal activities in the order-taking activities and provides supervision and guidance. In addition, its meetings, which are held twice a year, provide an opportunity to further educate and reaffirm the importance of compliance by sharing information on issues such as measures to be implemented throughout the Group and guidance for improvements in other departments.

We have established consultation desks for officers and employees (including temporary employees and seconded employees) of the Company and its Group companies and employees of business partners to consult with or report if they detect or suspect a compliance violation. Users may choose either the in-house consultation desk or external consultation desk (outside attorney). Consultations and reports may be made anonymously. Upon receipt of a consultation or report, the Compliance Committee will investigate the matter and, if necessary, may engage an independent expert or entity to conduct the investigation. After verifying the facts of the report, the Compliance Committee will consider and implement the necessary actions and responses. If it is determined that a compliance violation has occurred, corrective action will be taken and appropriate disciplinary action will be taken.

In order to promote fair, transparent, and free competition, the Kanadevia Group has established the following provisions in the “Kanadevia Group Charter of Ethical Behavior” to ensure compliance with the Antitrust Act and other laws and regulations concerning fair competition.

In addition, the Marketing Compliance Committee provides guidance and supervision of sales activities, while the Legal Department closely monitors trends in competition law and keeps internal rules and procedures up to date. In addition, we conduct an annual compliance e-learning program to raise awareness of competition laws.

Corrupt practices adversely affect free economic activity and hinder the realization of a transparent society. The Group has established anti-bribery rules to prevent bribery by the Group and its officers and employees, thereby ensuring compliance with anti-bribery laws and regulations in each country, preventing corruption, and establishing and maintaining fair business practices. The “Kanadevia Group Charter of Ethical Behavior” stipulates the following and strictly prohibits the involvement of officers and employees in corrupt activities.

In order to avoid the risk of corrupt practices, the risk of being involved in corrupt practices is carefully identified when orders are received. The Legal Department keeps a close watch on the latest international anti-corruption initiatives and keeps the compliance program, risk management, and internal controls in proper working order for new risks.

To properly implement export control aimed at international security, Kanadevia has established Security Export Control Regulations. Under the Representative Director, who is the highest responsible person, we have built an export control system consisting of the export control division (Legal Department) and each business department, and conduct strict export control for each individual case. To maintain the above export control system, we conduct education and audits every year. Furthermore, we have established a system to appropriately share information with internal related parties including management as well as Group companies about changes in the export control environment, including recent constantly changing export regulation and economic sanction revision trends in each country and their impact on business, from the Export Control Management Department, and have established a system to respond quickly and accurately to such environmental changes.

We promote compliance awareness by providing compliance training through seminars for each level of employment, including training seminars for new employees and new managers. Since 2004, we have also conducted annual compliance training through e-learning for all officers and employees to familiarize them with the Kanadevia Charter of Ethical Behavior and to act with a correct understanding of compliance with competition-related laws, such as the Antimonopoly Act, prevention of bribery and harassment, and other issues.

There were no instances of legal action taken or fines or penalties paid based on corrupt or anti-competitive behavior at the Company in the fiscal year ended March 31, 2024.