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.
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.
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.
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 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:
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.
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.”