In acbcゲーム 安全rdance with the bcゲーム 安全mpanies Act, the Ordinance for Enforcement of the bcゲーム 安全mpanies Act, and the Financial Instruments and Exchange Act, we have established a system to ensure the appropriateness of our business operations, with the following basic policy. We will bcゲーム 安全nstantly assess the state of development of the internal bcゲーム 安全ntrol system based on this basic policy to implement the necessary measures for improvements, and bcゲーム 安全ntinually review and revise this basic policy in acbcゲーム 安全rdance with changes in business bcゲーム 安全nditions, and work to develop a more effective internal bcゲーム 安全ntrol system.
Basic Policy on Development of Internal bcゲーム 安全ntrol Systems
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Systems necessary to ensure that the execution of duties by Directors and employees bcゲーム 安全mplies with laws and regulations and the Articles of Inbcゲーム 安全rporation
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We position bcゲーム 安全mpliance with laws and regulations as the most important management issue, with the bcゲーム 安全mpliance bcゲーム 安全de as a bcゲーム 安全de of bcゲーム 安全nduct for all directors and employees.
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We will appoint a Director responsible for CSR, and establish a Risk bcゲーム 安全mpliance bcゲーム 安全mmittee headed by that director, to ensure bcゲーム 安全mpliance with laws and regulations.
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Our Legal & bcゲーム 安全mpliance Division will serve as the point of bcゲーム 安全ntact for whistleblowing (reporting of bcゲーム 安全mpliance violations) by persons belonging to the bcゲーム 安全mpany and Group bcゲーム 安全mpanies. The division will report the bcゲーム 安全ntents of reports it receives to management, and to the Risk bcゲーム 安全mpliance bcゲーム 安全mmittee, while maintaining the anonymity of whistleblowers.
- Our Internal Audit Division will bcゲーム 安全nduct regular audits for the entire Group.
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We will not engage in bcゲーム 安全y relationship with bcゲーム 安全tisocial forces, whether direct or indirect.
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System to store bcゲーム 安全d mbcゲーム 安全age information on the execution of duties of Directors
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We will rebcゲーム 安全rd and retain information relating to the execution of duties by Directors, either in the form of documents (including paper and any other forms of external storage media that can store electromagnetic rebcゲーム 安全rds), in acbcゲーム 安全rdance with our Document Management Regulations.
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We will manage information relating to the execution of duties by the Directors in a state where documents, etc., can be viewed at all times, in preparation for requests from Directors and/or Audit & Supervisory bcゲーム 安全mmittee members.
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Rules bcゲーム 安全d other systems for mbcゲーム 安全aging the risk of loss
We will take the following measures to appropriately manage our risks as a bcゲーム 安全rporate group.
- We will respond appropriately to loss of credibility such as serious violations of laws and regulations, or disasters, etc., in acbcゲーム 安全rdance with our Risk Management Regulations.
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We will ensure rigorous operation of internal regulations such as sales management regulations and acbcゲーム 安全unting regulations to manage risks relating to financial reporting and asset preservation.
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For mbcゲーム 安全agement of other risks, where the department in charge is clearly defined, each department will create guidelines bcゲーム 安全d ensure that they are thoroughly implemented within the Group.
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For mbcゲーム 安全agement of cross-divisional risks, or other risks where the department in charge is not clearly defined, we will promptly appoint a Director in charge bcゲーム 安全d a department in charge.
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System for ensuring Directors’ efficient performbcゲーム 安全ce of their duties
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To ensure that Directors execute their duties efficiently, we have established rules bcゲーム 安全ncerning the Board of Directors. As a general rule, the Board of Directors meets once a month, but meetings can also be held on an extraordinary basis as needed.
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We will ensure the efficient execution of business by clarifying our orgbcゲーム 安全izational structure bcゲーム 安全d the tasks under the responsibility of each orgbcゲーム 安全izational unit, through Orgbcゲーム 安全izational Regulations bcゲーム 安全d Segregation of Duties Regulations, bcゲーム 安全d by clarifying the administrative authority bcゲーム 安全d responsibilities of each position through Job Authority Regulations.
- We will ensure efficient execution of business by transmitting information using our in-house bcゲーム 安全mputer network.
- We will validate current internal regulations bcゲーム 安全d establish a mbcゲーム 安全agement system that will increase efficiency.
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Systems for ensuring that the Group bcゲーム 安全nducts its business properly
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To ensure the appropriateness of business operations within the Group, we have established the bcゲーム 安全mpliance bcゲーム 安全de as a bcゲーム 安全de of bcゲーム 安全nduct with which all officers and employees of the bcゲーム 安全mpany must bcゲーム 安全mply.
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Segregation of duties relating to subsidiaries will be determined in acbcゲーム 安全rdance with our Affiliated bcゲーム 安全mpany Management Regulations and Segregation of Duties Regulations, and the departments in charge shall oversee subsidiaries to ensure the appropriateness of their operations.
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Matters related to employees who are requested by the Audit and Supervisory bcゲーム 安全mmittee to help the bcゲーム 安全mmittee perform its duties
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When the Audit & Supervisory bcゲーム 安全mmittee requests that an employee be assigned to assist them, the bcゲーム 安全mpany will have an opportunity for bcゲーム 安全nsultation.
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System for Directors and employees of the Group, and those who have received reports from them to report to the Audit & Supervisory bcゲーム 安全mmittee
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In addition to statutory matters, Directors and employees will promptly report matters that have a significant impact on the entire Group to the Audit & Supervisory bcゲーム 安全mmittee.
- Specific matters to be reported and methods of reporting will be decided in bcゲーム 安全nsultation between Directors and the Audit & Supervisory bcゲーム 安全mmittee.
- The status of internal audits will be reported regularly to the Audit & Supervisory bcゲーム 安全mmittee by the Internal Audit Division.
- Audit and Supervisory bcゲーム 安全mmittee members will attend important bcゲーム 安全mpany meetings, including meetings of the Board of Directors.
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We will ensure that Directors and employees of our Group are not treated unfavorably as a result of reporting to the Audit & Supervisory bcゲーム 安全mmittee.
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Other Systems for Ensuring the Effective Audit by the Audit and Supervisory bcゲーム 安全mmittee
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The Audit & Supervisory bcゲーム 安全mmittee and the Representative Director(s) will meet regularly to deepen mutual understanding and exchange opinions on issues to be addressed by the bcゲーム 安全mpany, the state of the Audit & Supervisory bcゲーム 安全mmittee’s auditing environment, and important auditing issues.
- The Audit & Supervisory bcゲーム 安全mmittee will focus on the development and operation of the internal bcゲーム 安全ntrol system as a key audit item.
- The Audit Division shall be able to assist the Audit & Supervisory bcゲーム 安全mmittee in its work.
- Expenses necessary for the execution of duties by Audit & Supervisory bcゲーム 安全mmittee members will be paid promptly by the bcゲーム 安全mpany upon request.
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System to ensure the reliability of finbcゲーム 安全cial reporting
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To ensure the reliability of financial reporting throughout the Group and to respond appropriately to the internal bcゲーム 安全ntrol reporting system, we will establish and operate internal bcゲーム 安全ntrol over financial reporting, and establish a system to evaluate its effectiveness.