Basic Guideline for Compliance
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 Group Code of Conduct” stipulates basic items that all employees must observe during their daily business.
Obligation of Officers and Employees to Observe Compliance
Officers and employees, including temporary and non-regular staff, have an obligation to be compliant 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.
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.
Further, MGC group officers and employees must cooperate with Compliance Committee investigations.
Compliance Consultation Desk
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.”
- In addition to officers and employees, 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 Consultation Desk.
If a consultation at the Compliance Consultation Desk is about a suspected violation of compliance, 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.
- Compliance Consultation Desk shall protect the privacy of consulters, reporters and persons cooperating with the investigation 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 such disadvantageous actions as transfer or discrimination due to the consultation or report or due to cooperation with an investigation. In the case of partner companies or customers, instructions will be given to the relevant department/group company so as to confer no disadvantage. However, if it becomes clear that the consultation or report is mad on false fact, this restriction shall not apply.