Compliance Sustainability
Basic Concept
Goldwin Group aims to be corporate group trusted by its stakeholders that fulfills its social responsibilities by conducting business activities in a sincere and fair manner while complying with laws and regulations and adhering to social standards and ethics. To realize this, we recognize that it is essential for each employee to act with a strong awareness of compliance.
We foster a corporate culture that does not permit fraud, by establishing the Corporate Code of Conduct and Employees’ Code of Conduct, both of which serve as the standards for employees to choose the appropriate action, ensuring that all employees are familiar with these standards.
Promotion Framework
We have built a compliance framework in collaboration between the Compliance Department and Internal Audit Office. Compliance activities are reported to Executive Management Meeting, with oversight and guidance from the Board of Directors. The Compliance Department reports the on-site status of the Corporate Code of Conduct and Employees’ Code of Conduct to the Board of Directors and Board of Auditors who monitor the status. Various compliance activities are reported at Executive Management Meetings, with oversight and guidance from the Board of Directors.
The Internal Audit Office cooperates in operating the internal whistleblowing system and in activities to raise employee awareness. The Information Security Committee (Information Technology Department), HR, General Affairs and Legal Departments cooperate in planning and conducting training, and in confirming and complying with laws and regulations.
Compliance Promotion
Goldwin and Group companies follow our internal whistleblowing system and ensure that external directors and auditors can express independent and objective opinions at Board of Directors and Board of Auditors meetings. We thereby ensure that directors and auditors perform their duties lawfully.
We thoroughly ensure that all employees fully understand laws and regulations, our corporate philosophy, our code of conduct, etc. during various workshops. We also confirm compliance with business procedures and manuals at each location through internal audits and internal control system assessments and prevent misconduct by monitoring financial data such as sales and payments on a monthly basis.
In addition to annual compliance workshops, we distribute the Compliance Card, a guide to the internal whistleblowing system, code of conduct, and standards of conduct, to all employees and instruct them to carry it always. We also strive in other ways to raise employee awareness of compliance issues.
In FY 2024, we conducted a compliance awareness survey on 1,334 people with a Goldwin Group email address and 834 Goldwin Group sales associates. We have reflected the results of their responses in compliance training and other measures related to thorough compliance awareness to help foster an awareness for compliance. We also conducted a self-check survey concerning corporate culture on 1,274 employees including those at Group companies, and 931 sales associates nationwide. Their responses to the compliance questions showed that they are highly aware of compliance and have a deeper understanding of it.
Through these activities, we will continue to keep track of compliance awareness among employees, and link the findings to training and measures.
Compliance Education
We conduct annual compliance workshops for all employees, including those at Group companies. In FY 2024, we held workshops for 2,917 employees (100% attendance) with the objective of promoting compliance, preventing corporate misconduct, and familiarizing employees with our internal whistleblowing system.
We also published 12 issues of Compliance News, our e-newsletter that encourages employees to think about compliance in terms of themes that are familiar to them, including: Are you ignoring harassment in the workplace? Are you thinking before posting on social media? Is your comment appropriate? We held a power harassment workshop for those in managerial positions (area managers, store managers), and it was attended by 122 managers.
We also send sales associates a compliance newsletter by mail to share our approach to compliance and to nurture awareness among every employee, in addition to familiarizing them with our internal whistleblowing system. In FY 2024, we also shared the results of our internal audit and the increase in compliance awareness among employees, and once again requested and supported compliance promotion at each store.
Internal Whistleblowing System
Goldwin Group deploys an internal whistleblowing system (corporate ethics hotline) for queries and reports on misconduct, violations of the law and corporate ethics, or any possible violation in execution of company business. Compliance includes adhering to laws and regulations and the various internal rules of the company. It covers matters such as bullying, harassment, anti-corruption, anti-bribery, illegal employment, and human rights violations. Queries and reports can be made anonymously, either to an internal contact desk or externally to a lawyer or a labor and social security attorney’s office.
We conduct thorough investigations and reviews based on the content of the reports or queries, respond to the person who raised the issue, and take action accordingly. Personal information is protected and kept confidential in accordance with the Whistleblower Protection Act, so that no one suffers any consequences in raising a query.
In FY2024, we continued to strengthen awareness of our internal whistleblowing system and contact points. In the compliance awareness survey, 93％ of employees responded that they knew about the internal whistleblowing system. We received a total of 44 consultations and reports in the three categories of suspected compliance violation, suspected harassment, personal relations in the workplace, and other, all of which have been dealt with appropriately.
Additionally, separate from the internal whistleblowing system, the Internal Audit Office accepts requests for interviews from employees through its audit activities. The content of consultations covered by these interviews includes not only harassment but also issues such as communication issues between supervisors and subordinates, and efforts are made to ensure employees can easily seek advice before the issues escalate.
As organizational improvement initiatives, items judged to require improvement are reported to the Board of Directors based on the results of self-check surveys concerning corporate culture. Depending on the content, individual reports may also be made to the President, Executive Officers, or other relevant parties.
Anti-corruption and Anti-bribery Initiatives
1. Internal initiatives
Based on the Corporate Code of Conduct, the Group has developed a system to systematically address anti-bribery. Specifically, the following two types of bribery-related activities are prohibited.
- The provision of hospitality, gifts, money, or other benefits to domestic or foreign public officials and other government personnel (including individuals working for organizations proportional to the government) for the purpose of obtaining / maintaining preferential treatment, or anything that causes such suspicion
- The exchange of hospitality, gifts, money, or other benefits with business partners or other persons for the purpose of obtaining / maintaining unfair benefits or preferential treatment
We will also comply with the Antimonopoly Act, the Subcontract Act, the Financial Instruments and Exchange Act, other relevant laws and regulations, internal company rules, and all applicable laws and regulations that prohibit insider trading, money laundering, bribery, coercion in transactions, and other improper transactions, and will not engage in any conduct that violates such laws and regulations.
2. Initiatives for suppliers
The Group established the Goldwin Group Supplier Code of Conduct as a set of fundamental principles for suppliers to be followed when conducting transactions with the Group and seeks their understanding of and compliance with the Code. Our anti-corruption and anti-bribery initiatives for suppliers are also stipulated in the Goldwin Group Supplier Code of Conduct, and we request submission of an agreement form when initiating new business relationships.
*For details, see “Supply Chain Management.”
Future Issues
We will continue to comply with laws and regulations, to observe social norms and ethics, and to meet societal expectations. To this end, we will share information about relevant laws, our corporate philosophy, and our code of conduct, conduct internal audits and internal control system assessments, operate our internal whistleblowing system, take rigorous efforts to prevent corruption, hold compliance training, and strive to foster compliance awareness among all employees. We will further develop and enhance the system to expand business domains in the future.