Anti-corruption / Fair Trade
Concept and Policy
The Daiwa House Group declares not only corporate compliance but also anti-corruption and prohibition of corrupt practices such as money laundering, embezzlement and obstruction of justice from the ethical viewpoint in accordance with various policies and rules such as the Daiwa House Group Principles of Corporate Ethics and Code of Conduct. The Group thereby stipulates that we shall conduct business transactions by ensuring transparency and fairness of business operations.
Basic policies on prevention of bribery
The Daiwa House Group sets forth in the "Principles of Corporate Ethics" not only the policy on prohibition of bribery but also the requirement of fair competition. In particular, it specifically stipulates as the measures against bribery that "we shall not offer any bribe to any politician or officer or staff member of any government or municipal office or local self-governing body" and that "we shall refrain from any act that may be suspected to be aimed at getting any favor for any permission, approval or the like even if such act is a legal donation, attendance at a social gathering or the like."
It also clearly stipulates for other fair competition that "we are prohibited not only from conducting any act infringing the principle of free and fair competition such as an illegal pricefixing agreement but also from making any information exchange, meeting or contact for any adjustment that may raise any suspicion" and that, "when we offer any entertainment such as dinner and a social gathering, we shall do it to the extent allowed by social common sense by taking in-house rules, etc., of an entertained person into consideration." Under such basic policies, all executives and employees share the awareness about the necessity of the suitable relationship with political and administrative entities.
Furthermore, as results of the overseas business expansion, the increase in the risk of offering bribes to foreign government officials accompanying such expansion and increased domestic and overseas desires to fur ther improve the systems for preventing offers of bribes, we consider it necessary to reinforce the system for prevention of offers of bribes. Therefore, it takes the following new measures:
- Development and determination of "Basic Policies on Prevention of Offers of Bribes" more specifically setting forth contents of "Principles of Corporate Ethics"
Under the "Business Principles for Countering Bribery" of Transparency International and the "Guidelines for the Prevention of Bribery of Foreign Public Officials" of the Ministry of Economy, Trade and Industry of Japan, the Daiwa House Group has developed and determined the "Basic Policies on Prevention of Offers of Bribes" and stated that it prohibits any bribery because it hinders fair competition and aggravates social corruption.
- Establishment of "Anti-Bribery Regulations" setting forth management system
On the basis of the "Basic Policies on Prevention of Offers of Bribes," we have established the "Anti-Bribery Regulations" in order to set forth the system, prohibited matters, procedures, etc., required to prevent its executives and employees from being involved in offers of bribes to public officials, etc., throughout the Group.
The main rules thereof are as follows: (1) selecting and appointing a director responsible for preventing offers of bribes; (2) establishing the consultation hotline and whistleblower hotline for ordinary times and emergencies; (3) prohibiting offers of benefits, etc., to public officials, etc., in principle and allowing exceptions through procedures, etc., for getting prior approvals; (4) controlling third parties such as agents; (5) giving training to persons engaged in overseas businesses; (6) conducting audits by the Internal Audit Department; (7) reviewing them by management; (8) taking disciplinary actions against persons violating the Rules; and (9) supporting the Group companies in improving their systems.
- Establishment of "Anti-Bribery Bylaws," etc., made applicable to practical business affairs
In fiscal 2017, we plan to establish the "Anti-Bribery Bylaws" by making the "Anti-Bribery Regulations" more specific and applicable to practical business affairs. It desires to address anti-corruption by making the contents of these Regulations and Bylaws, etc., thoroughly known to and enforced on its executives and employees.
Basic policy on fair trade
The Group has clearly stated that all executives and employees will abide by the principle of competition of a fair and free market in the Principles of Corporate Ethics to share the awareness to strictly observe the Anti-monopoly Act (Act on Prohibition of Private Monopolization and Maintenance of Fair Trade) and subcontracting law (Act against delay in payment of subcontract proceeds, etc. to subcontractors).
Policy regarding political contributions
We have complied with the Political Funds Control Act. We never make any political donations to individual politicians, which is prohibited under the law. Also, we do not make donations, in principle, to specific political parties or political fund-managing organizations. However, if we consider making contributions, we will make sure that such donations do not conflict with the restrictions specified in Article 22, Item 3 (1) of the Political Funds Control Act (restrictions on donations made by companies subsidized by the government). With regard to the purchase of fund-raising party tickets, as set forth in Article 8, Item 2 of the Act, we have made purchases in a legitimate manner. In addition, we will properly make expenditures on lobbying activities pursuant to the corporate compliance principles.
Guidelines for Transactions with Company for Own Interests of Directors, etc.
From the viewpoint of protecting the interests of shareholders, Article 11 of the "Corporate Governance Guidelines" sets forth the standards such as the "Guidelines for Transactions with Company for Own Interests of Directors, etc." to prevent the persons related to our Group, such as Directors and Auditors, and its major shareholders from conducting any transactions that may conflict with the interests of our Group or its shareholders through abuses of their positions.
We endeavor to prevent and detect any corrupt practices under the supervision of the Directors by developing internal monitoring systems such as the internal audit system and the whistleblower system in enforcing anti-corruption and complying with the principle of fair competition and trade. While it emphasizes the prohibition of offers of bribes in the "Code of Conduct" and endeavors to improve awareness through employee education, it collects written oaths from all executives and employees once every two years so that it can prevent any corrupt practices. In addition, it concentrates its efforts on early detection of problems with anti-corruption and compliance with the principle of fair competition and trade by carrying out survey questionnaires for business partners regularly.
Enforcement of anti-corruption with internal audits
To secure the transparency and fairness of business management pursuant to the Principles of Corporate Ethics, when asked for the investigation of corruption or illegal acts by the CSR Department or other relevant divisions, we conduct ad hoc internal audits to confirm the facts.
We have created the in-house supervisory mechanism, under which internal audits are implemented by Auditors and the Internal Audit Department; internal control activities over financial reporting are conducted by the J-SOX Department; issues are presented to the Risk Management Committee; and the Corporate Ethics and Human Rights Helpline is operated. We conduct corruption risk assessment by immediately making judgements on the information collected through such routes.
Enforcement of anti-corruption by Partners Hotline
As part of building an appropriate relationship with its business partners, the Daiwa House Group is operating "Partners Hotline" as a whistleblower hotline. This "Partners Hotline" is a mechanism of early detection and response to problems that may lead to the violation of law in the relationship of our employees and business partners. This whistleblower hotline receives information on any corruption or problem from the viewpoint of fair trade arising in the Group or the supply chain and addresses such corruption or problem.
Promotion of fair trade based on questionnaire survey toward business partners
The Daiwa House Group carries out questionnaire survey toward business partners to check on a worksite level if there are any incipient problems that may lead to the violation of law or other cases. After collecting the questionnaires, each worksite endeavors to prevent any corruption or problem with compliance with the principle of fair competition and trade from occurring and improve the situation by drawing up an improvement plan and conducting improvement activities.
Employee education on anti-corruption and fair trade
In order for all executives and employees will be able to make decisions and take actions pursuant to the Daiwa House Group Principles of Corporate Ethics and Code of Conduct, we have created and distributed "CASEBOOK," a textbook with concrete case examples and an educational tool for all employees, and read through it at morning meetings and other occasions. In addition, we endeavor to enrich the content of the "CASEBOOK" for meeting needs of the times by revising it regularly.