Fair Operating Practices(Risk and Compliance Management)

Risk and Compliance Management Policy

NuFlare Technology,Inc.(“NuFlare Technology”) stipulates, in our Standards of Conduct, that all our directors and employees should practice the basic behavioral principle of observing all relevant laws, regulations, contracts, ethics, and company rules, and promotes good faith and fair business activities.

Risk and Compliance Management Promotion System

The president of NuFlare Technology is also the Chief Risk & Compliance Management Officer (CRO) who assumes the ultimate responsibility for risk and compliance management for the entire company. When serious compliance-related issues arise, we have a system in place that allows the Risk Management Committee to convene to swiftly verify facts and discuss and implement measures to deal with the issues and prevent them from reoccurring.

Risk and Compliance Management Framework

Training on Risk and Compliance Management

We provide various training programs for new employees with a view to ensuring compliance with the NuFlare Technology Group Standards of Conduct. We also periodically provide our directors and employees with compliance training and department-specific legal training. We ran a training program on compliance guidelines in January 2018, followed by a case study-based compliance training program for general senior managers and managers in March 2018 (see photos). In addition to these training programs, individual employees are given the opportunity to deepen their understanding of compliance, safety, and related issues through CSR workplace meetings that are held by workplaces at regular intervals.

Training on Risk and Compliance Management

Response to Compliance Violations

In the event of a noncompliance incident, the CRO will convene a special Risk and Compliance Management Committee meeting to develop accurate understanding of facts, locate root causes, and disclose information in a proper and timely fashion, when deemed necessary, to prevent similar incidents from occurring. At the same time, the CRO will make appropriate responses, possibly including a punishment for an employee who has committed a compliance violation.

In-House Whistleblower System

In response to the Whistleblower Protection Act which came into force in April 2006, NuFlare Technology established a whistleblower system in May of the same year to collect internal information on NuFlare Technology Group Standards of Conduct violations, compliance violations, and the like, to promote early detection of such violations and prevent them. Under this system, we offer the following supports for our employees:

  • 1)Corporate Ethics Helpline
  • The helpline is set up mainly for the purpose of avoiding risks associated with compliance violations (e.g. violation of law and illegal trading). The help line also collects information and offers consultation on actions considered to be violations of laws and regulations, social norms, corporate ethics, NuFlare Technology Group Standards of Conduct, and other in-house regulations.
  • 2)Employee Help Desk
  • The help desk offers advice and assistance on the following matters:
  • ① Problems concerning the workplace and personal relations
  • ② Problems concerning personnel affairs
  • ③ Sexual harassment
  • ④ Discriminatory actions based on pregnancy, childbirth, childcare leave and nursing care leave, etc.
  • ⑤ Abuse of power and any other problems.
  • The system allows an employee (including an anonymous informant) to report an incident and seek advice by telephone, email, fax, post, or other means. NuFlare Technology has a structure under which an incident reported to the system is referred promptly to the CRO and auditors, so that an investigation can be established to solve the problem as early as possible.

Compliance Situation Inspection and Audit

The General Affairs Department works in coordination with the Internal Audit Office in order to confirm the state of implementation of various compliance measures and reflect audit results in compliance measures.

Prohibition of Political Contributions

The NuFlare Technology Standards of Conduct stipulate that NuFlare Technology “shall not make contributions to political parties or committees, unless permitted to do so by applicable laws, regulations, and company rules.”

<< NuFlare Technology Standards of Conduct >>