Compliance at the SAN HOLDINGS Group is not limited to simply complying with laws and regulations. As a member of society, we also have an obligation to adhere to high ethical standards. We are well aware of our responsibility to society to conduct business operations that are consistent with sound and generally accepted guidelines for proper behavior.
The Compliance Committee, which is responsible for overseeing all activities involving compliance, is an independent advisory unit for the Board of Directors. The committee establishes compliance policies, determines responses to compliance violations, discusses steps to prevent violations from happening again, and performs other duties. Decisions reached by the committee are passed on to the Board of Directors. In addition, the Compliance Committee has the authority to submit directives for corrective actions to the Board of Directors in the event of a serious violation of a law or regulation.
The General Affairs Department of SAN HOLDINGS functions as the secretariat for determining guidelines for compliance programs, establishing frameworks, conducting education programs and all other activities involving compliance.
The Code of Conduct contains guidelines and generally accepted thinking that everyone at the SAN HOLDINGS Group should observe when conducting business operations. To ensure that these guidelines are used for business operations, we have established Standards of Conduct that contain particularly important standards for behavior.
All executives and employees receive a SAN HOLDINGS Group Compliance Handbook and compliance training programs are conducted frequently.
Directors and executive officers strictly enforce standards for the behavior of everyone at the SAN HOLDINGS Group in order to prevent a violation of the Code of Conduct or Standards of Conduct. These individuals perform leadership roles for quickly performing investigations of violations, identifying causes and determining preventive measures. This system enables appropriate responses with the company assuming responsibility. If there is a defect concerning a service or product, a clear and suitable explanation is promptly announced. Furthermore, responsibility for the issue is quickly disclosed and thorough actions are taken in order to earn the understanding of the public. If necessary, directors or executive officers may accept responsibility for a problem involving a service or product and decide to penalize themselves.
We operate a Help Line that allows individuals at our group to contact the secretariat of the Compliance Committee with information about possible violations of the Code of Conduct or Standards of Conduct.