Compliance

Basic Approach on Compliance

We have established Compliance Rules and Corporate Code of Conduct with the aim of ensuring thorough Compliance and enhancing social credibility, and are making it widely known throughout the company that executives and employees must comply in the course of their day-to-day operations.

We recognize that thorough compliance with these principles is the basis of our Compliance, and we are promoting activities to instill compliance with laws, social ethics, corporate codes, etc. among all employees.

By ensuring that all employees comply with laws, regulations, company rules, etc., and conduct corporate activities based on high ethical standards, we will meet the trust of our customers and all other stakeholders and fulfill our corporate social responsibilities.

Corporate Code of Conduct

1) With our customers

We will strive to provide high-quality products and services by pursuing customer security and satisfaction.

We will respond to customer complaints and requests promptly and in good faith.
We will not neglect our efforts to earn the trust of our customers.
We will comply with all laws and regulations and ensure the protection and management of customers' personal information and privacy.

2) With Our Business Partners

We will cooperate with each other in good faith to increase corporate value.

Maintain sound and good relationships with business partners and do not abuse dominant positions.
We will eliminate unreasonable benefits and conveniences from each other and conduct fair and transparent transactions.
We will respect each other's intellectual property and endeavor to protect their rights.
Management of information obtained in the course of business shall be thoroughly implemented, and strict prevention of leakage and leakage of confidential information and personal information shall be implemented.

3) With Our Employees

We aim to be a company that respects the humanity of each and every employee and that can demonstrate its autonomy and creativity.

We will strive to maintain and improve our personnel system and working conditions so that we can feel a sense of accomplishment.
We will respect privacy and human rights, and will not tolerate any forms of discrimination or harassment.
We will comply with workplace rules and laws and create a sound working environment.

4) With Our Shareholders

We will strive to expand our corporate value, distribute the results of these efforts, and practice transparent and sound management.

We will disclose corporate information in a timely and appropriate manner.
We will actively promote IR activities and endeavor to understand each other with our stockholders.
We will thoroughly manage internal information and prevent insider trading.

5) With Society

We will comply with laws and regulations as a good corporate citizen, do not neglect environmental issues, and strive for Social Contribution Activities with morality.

We will not be involved in any antisocial forces that threaten the order and safety of civil society.
We will fulfill our social responsibilities as a company by engaging in two-way communication with society through wide-ranging public relations activities.
We will do our utmost to ensure that our business activities and the products and services we provide do not place a burden on the global environment.
We will not only comply with domestic and overseas laws and regulations, but also respect cultural and customs, maintain good relations with local communities, and actively make Social Contribution Activities.

Basic Approach on the Elimination of Antisocial Forces and Its Development Status

Corporate Code of Conduct stipulates that we are not involved in any anti-social forces that threaten the order and safety of civil society.

This information is posted on our WEB bulletin board, which is accessible to all employees, and we promote awareness-raising throughout the company by inviting outside experts as needed to hold seminars.

Compliance Control System

Compliance Committee

We have appointed Compliance Committee committee member Chairman, who is responsible for the core roles of Risk Management, and have established Compliance Committee under the chairman of committee member.

Committee member Committee meets on a quarterly basis to share perceived concerns about various internal risks. The committee also works to resolve issues as appropriate, for example by inviting outside experts as needed to hold seminars.

Compliance training

We conduct ongoing Compliance training for our directors and employees to ensure legal and ethical compliance.

The training is carried out separately for each position, with the aim of acquiring the laws and disciplines related to each work and the various risks surrounding the company.

Through these efforts, we are strengthening company-wide efforts to raise the awareness of Compliance among all executives and employees, and not only to violate laws and regulations, but also to prevent misconduct that would cause them to deviate from common sense.

Risk Management Committee

We hold Risk Management Committee meetings as circumstances warrant to ensure the safety of our executives, employees and our assets in the event of a crisis. These meetings are designed to prevent damage from spreading.

Risk Management Committee is under the direction of the president. secretariat is established in the General Affairs Department and the Corporate Planning Department, and the General Manager of the General Affairs Department and the Corporate Planning Department oversee the administrative affairs.

The definition of our crisis is a generic term for each of the following risks.

Corporate threats, sabotage, kidnapping, robbery, theft, fire and explosion, terrorism

Defective products and consumer complaints

Credit uncertainty, bankruptcy of business partners, problems with business partners, information (personal information) leakage, etc.

Dismissal restructuring, industrial accidents, discrimination against human rights, harassment, labor disputes, invasion of privacy, internal misconduct, etc.

Fluctuations in interest rates, foreign exchange rates, and stock prices

Typhoons, earthquakes, wind and water, and other natural disasters

Sanyo Alarm System (Compliance Hotline System)

We are working to enhance our Compliance system under the leadership of Sanyo Alarm System, which accepts reports on Compliance from employees and business partners, in order to prevent actions that could damage our reputation.

In the operation of Sanyo Alarm System, the content of reports is kept confidential, and it is clearly stated in the Alarm System Regulations that no adverse treatment shall be undertaken against whistleblowers, and all possible measures are taken to protect whistle-blowers.

Business partner compliance consultation/reporting desk

Human Rights Risk Management

Sanyo has positioned Compliance Committee as a Supervision agency for identifying and managing human rights risks within the company and in the supply chain.

Committee member Committee discusses various human rights issues and works to improve them.

Human rights risk assessment process

1. Identification of human rights risks

Utilization of international indicators and tools

Consultation with outside experts

2. Establishment of human rights risk items by referring to international codes

10 principles defined by the United Nations Global Compact in four areas (human rights, labor, the environment, and anti-corruption)

Requirements of ILO's Declaration on Fundamental Principles and Rights at Work

3. Establishment of priority risk items in the supply chain by referring to the International Code

United Nations Guiding Principles on Business and Human Rights

OECD due diligence guidance for responsible business conduct based on the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises

4. Set the range of risks and high-priority risks.

Scope of risks	Risks of high importance	Risk Management
In-house and consolidated subsidiaries	Harassment Discrimination Long working hours	Sanyo Alarm System
Domestic and overseas supply chains	Rights concerning labor of foreign nationals Long working hours Human rights issues related to the environment	CSR procurement

In accordance with the United Nations Guiding Principles on Business and Human Rights, we conduct human rights due diligence on the supply chain of our consolidated subsidiaries while exchanging opinions with outside experts.

First, we have used international indicators and tools to identify human rights risk items. Human rights risk items were comprehensively extracted from international norms and standards related to corporate social responsibility. Items related to society, human rights, and labor were added to the list of priority Risk Management items in the supply chain.

We assessed the 10 principles in the four areas stipulated by the United Nations Global Compact (Human Rights, Labour, Environment and Corruption Prevention) and the requirements of the Declaration on Fundamental Principles and Rights at Work by the International Labour Organization (ILO) as more important risk items.

As a result of our human rights risk assessment with external experts, we have identified the range of businesses in our supply chain where human rights issues such as forced labor and child labor are likely to arise.

We conduct CSR Audit in accordance with Sanyo Code of Conduct (SANYO Code Of Conduct), which aims to prevent human rights issues from occurring in the supply chain and provide guidance for improvement. We also regularly visit our domestic and overseas trading plants on site.

Basic Approach and Status of Internal Control

In 2006, we established Internal Control Committee, which reports directly to Management Meeting, with the aim of establishing an internal-control system that ensures the proper and appropriate execution of business operations based on Basic sustainability policy, employment regulations, and various rules.

Subsequently, the Internal Control Promotion Office was established in January 2007 as an organization to promote the development of internal controls. Following the reorganization in the same year, the internal control function was transferred to Internal Audit Office, which reports directly to the president, and was integrated.

In addition, we have put in place a Sanyo Alarm System (Compliance Hotline System) that accepts reports from employees about Compliance in order to prevent actions that could damage our social confidence.

Focusing on Internal Control Committee and Internal Audit Office, the Group will continue to strive to reform and improve its operations, once again analyzing and evaluating the risks associated with its current operations, business processes, and IT systems. These risks are closely related to the Group's operations.

Internal control promotion system

Internal Control Committee

We have established Internal Control Committee under the direct control of Management Meeting with the aim of strengthening and enhancing our internal control system, and we are working to develop the system and promote its effective operation.

Committee member Committee is composed of the president as the general manager, committee member president appointed by the president, and representatives from the following divisions (division heads or equivalent persons appointed by division heads) as well as divisions in charge of internal control development. The committee is the body that makes decisions on matters related to internal control of the Group.

Departments in charge of corporate planning
Divisions in charge of accounting or finance
Department in charge of legal matters
Division in charge of information systems
Department in charge of human resources
Division in charge of Internal Audit
Department in charge of general affairs
Division in charge of business operations
In addition, a person designated by committee member Director.

TIMELESS WORK. SANYO