Anicom Group Basic Policy on Compliance
At the Anicom Group, we uphold the management philosophy of “respect for the uniqueness of all creatures” and believe that by “working all together, through the division of work, we can spread ‘Thank You’ throughout the world.” in conducting day-to-day business.
We are still a young group with limited capital, and we believe that, in order to be useful to our customers at the minimum cost, we must continue to earnestly fulfill our promises to them and become worthy of their trust as a group. To this end, the senior managers and all other officers and employees who compose the Anicom Group (including temporary and part-time staff) shall comply with this policy as a guidepost that marks the straight and undeviating path to being useful for our customers.
1. Compliance with Laws, Regulations, and Rules
We shall obey laws, regulations, and internal rules, engage in fair and free competition, and undertake honest and appropriate corporate activities.
- （1）Compliance
Compliance refers to obeying laws, regulations, internal rules, etc. and undertaking honest and appropriate corporate activities. It is only by correctly understanding and strictly obeying all rules related to corporate activities that we can undertake appropriate corporate activities. - （2）Fair and free competition
We shall comply with the Insurance Business Act, the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade, and other relevant laws and regulations in the execution of business. We shall never engage in collusion, cartels, or other acts that impede fair and free competition; nor shall we ever use our bargaining power to unjustly coerce a counterparty to accept unfavorable conditions. - （3）Preventing conflicts of interest
We shall manage transactions that risk unjustly damaging the interests of customers or other Group companies as “transactions with potential conflicts of interest” in accordance with the relevant laws and regulations. We shall never tolerate actions intended to achieve one’s own benefits or that of third parties in conflict with the rightful interests of the Company. - （4）Protecting intellectual property rights
We shall pay adequate attention to avoiding any violation of intellectual property rights such as copyrights, patents, or trademarks. - （5）Workplace environments
We shall comply with laws, regulations, and other rules related to labor and employment, and endeavor to maintain safe and healthy workplace environments.
2. Relationships with Society and Politics
We shall maintain appropriate relationships with society and politics.
- （1）Attitude to antisocial forces
We shall maintain a firm attitude to antisocial forces such as crime syndicates and corporate racketeers, and shall not submit to their pressure. - （2）Attitude to suspicious transactions
We regard the implementation of money laundering and terrorism financing countermeasures as a key management issue. We recognize and understand the importance of these countermeasures, and we shall engage in building a framework for internal control. - （3）Political activities and political funding
We shall firmly maintain a fair attitude regarding elections, political activities, political funding, etc., in compliance with the relevant laws, regulations, and other rules. - （4）Bribery, business entertainment, gifts, loans, etc.
We shall never use our business position to engage in bribery, the exchange of money or goods, or other actions to gain unfair benefits; nor shall we provide or accept socially inappropriate business entertainment or gifts. As officers or employees, we shall not engage in lending or borrowing money with trading partners or other business associates or with other officers or employees.
3. Appropriate and Highly Transparent Management
We shall strive for appropriate business operations, engage in timely and appropriate information disclosure, and endeavor to ensure highly transparent management.
- （1）Timely and appropriate information disclosure
We believe that the timely and appropriate disclosure of various forms of management information is crucial. This is also true from the perspective of enhancing customer trust. We shall endeavor to actively disclose various information, including information submitted to regulatory authorities, to facilitate reasonable decision-making by shareholders, investors, customers, and others. - （2）Accurate information preparation and management
We shall prepare accurate records of management information and strictly manage these records to enable timely and appropriate information disclosure. We shall also cooperate honestly and sincerely with internal and external audits and investigations. - （3）Handling of confidential information
We shall strictly manage the various types of confidential information in accordance with internal rules and never disclose such information to, or use such information with, anyone except the persons concerned.
4. Respecting Human Rights
We shall respect the basic human rights of customers, Group officers and employees, and all other people.
- （1） Prohibition of discrimination
We shall mutually respect diverse values, individuality, and privacy, and shall never tolerate discrimination or human rights violations for any reason, such as gender, age, occupation, nationality, race, sexual orientation, disability, ideology, beliefs, religion, social status, or family background. - （2）Prohibition of harassment
We shall not tolerate any form of harassment, such as sexual harassment or abuse of authority. - （3）Handling of personal information
We shall obey the relevant laws and regulations, as well as the privacy policies established by each Group company, to avoid any violation of personal privacy. We shall exercise due caution in the management of customer information and other personal information, and shall never use this information for any purpose not necessary for business operations.
5. Examples of Specific Initiatives
- （1） We publish regular compliance newsletters for all employees on the themes established in the Group Compliance Manual, which is based on this basic policy, such as eliminating antisocial forces, preventing money laundering, eliminating unfair business practices (such as the abuse of a dominant bargaining position), the prohibition of insider trading, preventing corruption such as business entertainment and gifts, and the duty of confidentiality regarding company information. In this way, we endeavor to thoroughly disseminate and strengthen compliance awareness.
- （2） We implement regular tests to check the level of understanding among all employees, based on the compliance newsletters described in (1) above.
- （3） Senior managers convey to all employees regular affirmations of their commitment to compliance.
6. Authority for Revision and Abolition
This policy shall be revised or abolished by resolution of the Board of Directors of Anicom Holdings, Inc.
Established within the provisions of the Compliance and Risk Management Manual:
May 27, 2005
Established: November 14, 2007
Revised: August 14, 2008
Revised: January 15, 2009
Revised: December 14, 2011
Revised: October 27, 2017
Revised: May 1, 2020
Revised: May 1, 2020
Compliance Promotion System
The Management Committee and the "Group Compliance Committee" formulate measures to promote compliance, and inspect and confirm the status of implementation, while the Compliance Key Persons (KP), who are the person in charge (President and General Manager), and Compliance Risk Management Leaders are assigned to each organizational unit of Group companies and divisions, with our Compliance Promotion Department taking the lead in ensuring that all employees are aware of compliance.
Compliance Program
The Board of Directors has approved the "Compliance Program" as a company-wide compliance implementation plan, and is working on the establishment of a compliance system and training programs. The status of implementation of the Compliance Program is regularly reported to the management through the Board of Directors.
Compliance Manual
The "Group Compliance Manual" has been prepared as a guide to compliance in the execution of all business operations of the Group, and the contents of this manual are disseminated to all officers and employees. The manual consists of two parts: a structure for thorough compliance and general compliance rules. It describes in an easy-to-understand manner the regulations concerning compliance with laws and regulations, laws and regulations to be complied with by officers and employees, and explanations of case examples. It also specifies where to report any conduct that may violate laws, regulations, or internal rules, and establishes a system for confirming and investigating the facts regarding such conduct.
Compliance Education and Training
We conduct various types of training and confirmation tests, including workplace-based training, training at the time of hiring, department- and theme-specific training depending on job level and position, and comprehension confirmation tests for all employees, to ensure that all employees are thoroughly familiar with compliance rules and that compliance is integrated into various types of work.
The Compliance Promotion Department, as the department in charge of compliance training, plans and implements compliance-related training in cooperation with the Human Resources Department and other departments.
Various Compliance-related Inspections and Monitoring
The Group conducts inspections of important laws and regulations and theme-specific laws and regulations by the Compliance Promotion Department, with a focus on the status of compliance, to prevent and detect early any actions that may violate laws, regulations, or internal rules.
In addition, the Internal Audit Office checks the appropriateness and effectiveness of each department's internal control system in general and provides guidance for improvement, etc., while Audit & Supervisory Board Members attend important meetings such as Board of Directors and Group Compliance Committee, hear from the Compliance Promotion Department and the Internal Audit Office of the Company and Anicom Insurance, and conduct individual audits of each department.
Internal Reporting System
The "Group Basic Policy on Internal Whistleblowing" requires that any employee who discovers a compliance problem (including questionable cases) must immediately report it to the Compliance Promotion Department, etc. In cases where it is difficult to consult with the internal or Group whistleblower, the Company has established a system that allows employees to report and consult with whistleblowers outside the Group.
Group Risk Management Policy on Money Laundering and the Financing of Terrorism
The Company has established the "Group Risk Management Policy on Money Laundering and the Financing of Terrorism" and confirms counterparties and transactions to ensure that they are not involved in the transfer of criminal proceeds or the financing of terrorism.
The Anicom Group (hereinafter, the “Group”) regards the implementation of countermeasures to combat money laundering and the financing of terrorism (hereinafter, “Money Laundering and Terrorism Financing Countermeasures”) as a key management issue. The Group recognizes and understands the importance of these countermeasures, and is engaged in building a framework for internal management based on the risk management policy set forth below.
Article 1. Organizational Framework
- （1） Officers and employees, including senior management, shall recognize and understand the importance of Money Laundering and Terrorism Financing Countermeasures, and shall engage in these countermeasures autonomously and proactively.
- （2） The Group shall build a centralized management framework with a designated person in charge and a controlling department to manage the Money Laundering and Terrorism Financing Countermeasures. The countermeasures shall be implemented across the entire organization, through coordination between the relevant departments.
- （3） The Group shall clearly define the roles and responsibilities of the relevant departments regarding the Money Laundering and Terrorism Financing Countermeasures, based on the three lines of defense approach, and shall build a framework to implement the countermeasures in a timely and appropriate manner.
Article 2. Money Laundering and Terrorism Financing Countermeasures Based on a Risk-Based Approach
- （1） The Group shall adopt a risk-based approach to identify and assess the risks it faces related to money laundering and the financing of terrorism, and shall undertake mitigation measures appropriate for these risks.
- （2） The Group shall regularly verify the effectiveness of its identification and assessment of risks and its mitigation measures, and shall revise them as appropriate.
- （3） The Group shall implement appropriate transaction monitoring and filtering, and shall build a framework to accurately detect, monitor, and analyze suspicious customers and transactions.
Article 3. Checks at the Time of Transactions and Customer Management
In addition to implementing checks at the time of transactions in accordance with the relevant laws and regulations, the Group shall appropriately manage the details, status, etc. of each customer’s transactions. In the case of transactions or other dealings with inappropriate customers, including antisocial forces, for which the Group believes that it cannot implement the customer management it prescribes, the Group shall endeavor to refuse transactions or otherwise prevent risks.
Article 4. Reporting Suspicious Transactions
- （1） The Group shall promptly report any transactions it believes fall under suspicious transactions to the Financial Services Agency, using the designated format.
- （2） The Group shall analyze information such as the details and tendencies of suspicious transactions reported in the past, and utilize this to upgrade its risk management framework related to money laundering and the financing of terrorism.
Article 5. Economic Sanctions and the Freezing of Assets
The Group shall appropriately implement measures based on regulations and controls in Japan and overseas, such as the elimination of business relationships with those subject to sanctions and the freezing of assets.
Article 6. Training
The Group shall continuously implement training for all its officers and employees as necessary and appropriate in view of their roles. The Group shall endeavor to deepen the understanding of preventive measures associated with the Money Laundering and Terrorism Financing Countermeasures across the entire organization, and maintain and enhance the expertise and conformance of its officers and employees.
Article 7. Revision and Abolition
This policy shall be revised or abolished by resolution of the Board of Directors, upon the proposal of the General Manager of the Compliance Promotion Department.
Established: December 16, 2019
Anti-Corruption Initiatives
The "Group Basic Policy on Compliance" stipulates that the Company shall maintain a fair attitude toward elections, political activities, political funds, etc., in compliance with various laws and regulations.
The Company will not engage in any bribery using its position in the business, obtaining any other improper benefits such as money or goods, or giving or receiving any socially inappropriate entertainment or gifts. In addition, officers and employees will not borrow or lend money to or from business partners or between officers and employees.