Compliance System

In order to implement management in such a way as to emphasize compliance, the following systems and organizations are in place.

Formulation of new “Compliance Regulations” and “MGC Code of Conduct”

The “Compliance Regulations” define items necessary to the MGC compliance system. The “MGC Corporate Behavior Guidelines” in the “Compliance Regulations” act as the basic guidelines for the compliance system. Separate from the regulations, the “MGC Code of Conduct” stipulates basic items that all employees must observe during their daily business.

Establishment of a Compliance Committee

A Compliance Committee is being established to preside over the compliance system, prevent misconduct before it occurs, and also to deal with individual cases of compliance violation.

Establishment of a Compliance Consultation Desk

A Compliance Consultation Desk is being established to assist with confusion over judgments concerning compliance problems, and for cases in which compliance violations are not, or it is feared will not be, rectified via the corporate system.

Compliance Consultation Desk Contact Information

Officers and employees, including temporary and no-regular staff, have an obligation to observe compliance, and should they become aware of any violations of compliance, to rectify these via the corporate organization.
The first principle of compliance is that problems are resolved within the existing corporate organization, that is, within everyday work.

The “Compliance Committee” presides over compliance for the corporate group, under the direct control of the president.
Compliance committee are composed of the compliance officer as the chairperson, directors, and the head of compliance-related departments, and have the below duties.

1. Establish and discuss group compliance system, policies and measures etc.
2. Ascertain status of group compliance, and provide guidance/supervision as needed
3. Conduct investigations, corrective measures, reoccurrence prevention and discussions with regards to compliance violations

The policies, guidance/supervision related to compliance discussed and established by the Compliance Committee, and corrective measures and reoccurrence prevention related to violations will be reported to the president and board of auditors, and implemented as per standard company procedure.
Further, MGC group officers and employees must cooperate with Compliance Committee investigations.

When there is confusion over judgments concerning compliance problems, advice can be received from the Compliance Consultation Desk.
Furthermore, if compliance violations (or feared violations) are not, or it is feared will not be, rectified via the corporate system, the facts of the violation or information sufficient to make the accusation of compliance violation believable must be reported to the “Compliance Consultation Desk.”

Compliance Consultation Desk Contact Information

1. In addition to officers and employees, their the families, partner companies, customers, and anyone involved in business activities with MGC group can consult with or provide information to the Compliance Consultation Desk.
2. As a rule, the Compliance Consultation Desk will require that you reveal your department and name for consultations and reports so that you can be contacted with the results of deliberations and to deter malicious libel and slander. Further, you are requested to make your consultations and reports by letter, FAX, e-mail or other media that leave a record. However, if there are deemed to be unavoidable circumstances, the only Compliance Committee secretariat division will accept anonymous phone calls or FAXes.
3. All consultations at the Compliance Consultation Desk will be immediately reported to the Compliance Committee chairperson in cases where it is possible that a serious compliance violation has occurred. The Compliance Committee will conduct investigations of fact relevance, take necessary measures such as corrections and reoccurrence prevention, and inform the consulter/reporter of the results.
4. Compliance Consultation Desk shall protect the privacy of consulters and reporters and shall not reveal their names nor the fact that they made a report to anyone other than the concerned parties.
5. MGC group officers and employees who make consultations and reports shall not be reprimanded, disciplined, transferred, or discriminated against due to the consultation or report. In the case of partner companies or customers, instructions will be given to the relevant department/group company so as to confer no disbenefit.
   However, if the consultation or report is made with the objective of framing another person, or with the objective of pressuring, blackmailing or other illegal motives, this restriction shall not apply.