The Happinet Group understands and acts in accord with the purpose and spirit of all relevant laws and regulations, and even if a gap in the law is apparent, we will not intentionally exploit it.
Furthermore, we adopt a vigilant approach to self-regulation with regard to operating in compliance with laws and regulations. If there is a violation of law, or if we recognize the possibility of such, we will respond in a systematic manner and take corrective action at the earliest possible stage.
To verify that each business division is conducting its business activities in a proper manner and to enhance the effectiveness of compliance, the Happinet Group has established a Compliance Promotion Office under the direct oversight of the President.
Based on our Internal Audit Plan, this Office works in cooperation with auditors while efficiently and effectively conducting internal audits related to all aspects of our business operations.
The Happinet Group has instituted the Happinet Group Compliance Program for the purpose of enhancing the effectiveness of compliance. Under this program, the filing of a report prompts the Internal or External Compliance Committee to investigate and determine whether any illegal action has been committed. If it so happens that a violation of the law is discovered, we will promptly determine and execute punitive and corrective measures, precautionary action, and measures to prevent a recurrence.
During fiscal 2013, there were no serious violations of laws and regulations.
The Happinet Group has instituted a Code of Ethics aimed at helping us achieve our Group Vision. The content focuses on social norms and achieving harmony with society, and it is intended to set the standard for the business activities of the Group. The Code of Ethics is divided into "Basics" and "Practical Guidance." To promote understanding among employees throughout the Group, the "Basics" section is distributed to all Group employees and the "Practical Guidance" section is posted on the company intranet.
In addition, we have set up an Ethics Review Committee to make periodic revisions to the Code of Ethics reflecting changes in the business environment or in the nature of business activities. In fiscal 2013, the Ethics Review Committee developed a Social Media Basic Policy.
To ensure thorough compliance, we conduct ongoing employee training for the Group as a whole. We also provide training opportunities for new employees on the Code of Ethics and other topics.
The Happinet Group has established both Internal and External Compliance Committees under provisions of the Happinet Group Compliance Program. The Internal Compliance Committee is made up of the COO, CFO, and other designated members; the External Compliance Committee is composed of outside directors.
When compliance-related matters arise, employees can pursue the standard business-reporting route or follow an additional channel that enables employees to report tips anonymously to the Internal or External Compliance Committee. Employees who utilize this system to make a report or seek consultation shall not be penalized in terms of their status or treatment within the company, regardless of whether or not an investigation uncovers compliance issues.