MGC Corporate Behavior Principles and MGC Group Code of Conduct
To practice management that prioritizes compliance, the MGC Group positions the MGC Corporate Behavior Principles as a fundamental principles that expresses in concrete terms how compliance should be addressed, and the MCG Group Code of Conduct states fundamental items that officers and employees must observe when acting in the course of day-to-day business.
Obligation of Officers and Employees to Observe Compliance
In the MGC Group, officers and employees, including temporary and non-regular staff, have an obligation to ensure compliance, and should they become aware of any violations of compliance, to rectify these via the corporate organization. In addition, if officers and managers with responsibility for organizations become aware of the possibility or fact of a compliance violation, they are obligated to promptly investigate, take appropriate corrective measures, and take measures to prevent reoccurrence.
The first principle of compliance is that problems are resolved within the existing corporate organization, that is, within everyday work.
Further, MGC Group officers and employees must cooperate with Compliance Committee investigations.
Notification of Violations
Prompt and accurate notification of compliance violations must be provided. The sooner the Company discovers a compliance violation, the faster it can take effective action. In the MGC Group, officers and employees are not subject to any disadvantageous treatment, such as transfer or discrimination, on the grounds of reporting conduct that constitutes or may constitute a compliance violation.
In addition, officers and employees are not subject to any such disadvantageous treatment on the grounds of cooperation with an investigation.
The privacy of individuals who make reports or cooperate with investigations is also protected. Any person who subjects another to disadvantageous treatment in violation of this rule is subject to admonishment or other disciplinary action.
Responses to Violations
If an officer or employee commits a compliance violation, such person may be subject to admonishment or other disciplinary action in accordance with the Employment Rules.
As an independent organization under the direct control of the president, the “Compliance Committee” deals with each event of compliance violation.
The Compliance Committee is composed of the Compliance Officer (Chairperson), director(s)（Vice Chairperson）, and the head of compliance-related departments.
The result of activity by the Compliance Committee will be reported to the president, the Board of Directors, and Audit & Supervisory Board. The countermeasure against each event of compliance violation will be discussed and resolved by the Compliance Committee, and implemented as per standard company procedure.
When there is confusion over judgments concerning compliance problems, advice can be received from the Compliance Hotline.
Furthermore, if compliance violations are not corrected or are not likely to be corrected through the corporate organization, the facts of the violation or information sufficient to make the accusation of compliance violation believable must be reported to the “Compliance Hotline.”
- In addition to officers and employees (including former officers and employees who separated from the Group within one year), their families, affiliated companies, partner companies, customers, and anyone involved in business activities with MGC Group can consult with or provide information to the Compliance Hotline. Consultations on personal legal matters and advice on matters unrelated to the business of the MGC Group are not provided, and opinions on policies and other matters unrelated to compliance as well as false consultations and reports are not accepted.
- In principle, consultations and reports should be submitted by a means that leaves a record such as letter, facsimile, or email. Anonymous consulting and reporting are permitted, but it is necessary to request contact information so that notification from the Compliance Hotline on the outcome can be provided.
- The Compliance Hotline shall protect the privacy of consulters, reporters and persons cooperating with investigations and shall not reveal their names nor the fact that they made a report to anyone other than the concerned parties.MGC Group officers and employees who make consultations and reports shall not be subjected to disadvantageous treatment such as transfer or discrimination due to the consultation or report or due to cooperation with an investigation. In the case of a partner company or customer, instructions will be given to the relevant department or Group company so as to confer no disadvantage. However, if it becomes clear that a consultation or report was made on the basis of false facts, this restriction shall not apply.
- If a consultation with the Compliance Hotline concerns a suspected compliance violation, the Compliance Committee will investigate the facts, take necessary measures such as corrective measures and prevention of reoccurrence, and inform the consulter or reporter of the outcome. If any Compliance Committee or Compliance Committee Secretariat member is an interested party to a matter concerning a consultation or report, such person shall not be involved in that matter.
- If a determination is made that a consultation or reported matter submitted to the external consultation desk is a significant issue relating to the Company’s operation or management, the report may be made directly to an Outside Audit & Supervisory Board Member. The same applies if the response by Compliance Committee or other internal organization is inadequate and an appropriate response cannot be expected, or if the reporting individual refuses to provide information to the Compliance Committee Secretariat.