1.Anicom Holdings, Inc. (hereinafter, the “Company”) shall establish a group-wide internal whistleblowing system (hereinafter, the “System”) for the purpose of increasing the soundness of group management and maintaining and enhancing corporate value through the prompt detection of legal and regulatory violations and violations of internal rules, etc. and the prevention of scandals at the Company and its subsidiaries (hereinafter, the “Company, etc.”), and the implementation of necessary corrective measures and measures to prevent any recurrence.
2.The Company shall establish the Group Internal Whistleblowing System Operating Rules for the appropriate operation of the System, protect the users of the System based on these rules, and endeavor to increase trust in the System.
Eligible Users of the System
Article 2.
1.The following persons shall be eligible to use the System (those listed under (1) or (2) are collectively referred to as “Officers and Employees, etc.”).
(1)Officers (Directors and Audit & Supervisory Board Members) and employees (including contract workers, part-time and casual staff, temporary staff, and staff seconded from elsewhere) of the Company, etc.
(2)Officers and employees of other business operators with a contractual relationship with the Company, etc.
(3)Persons who have been employees of the Company, etc. or other business operators with a contractual relationship with the Company, etc. within one year from the date of whistleblowing.
2.Eligible users may make anonymous reports.
Facts to Be Reported
Article 3.
1.Facts to be reported under the System shall include acts by Officers and Employees, etc. that violate laws, regulations, or internal rules, or constitute human rights violations or other harassment, or acts that may potentially constitute such violations, harassment, etc.
2. Eligible users may also use the System for consultations regarding the structure of internal whistleblowing and issues such as unfavorable treatment, in addition to the previous paragraph.
3.Fraudulent or dishonest reports and consultations, including those made in full awareness that none of the facts to be reported under Paragraph 1 above have occurred or are about to occur, reports made for the purpose of fraudulently attaining benefits, or reports made for the purpose of slandering or defaming others, shall not be accepted.
Whistleblowing Contact Points
Article 4.
1.In addition to internal contact points handled by the Company’s Compliance Promotion Department and standing Audit & Supervisory Board Member, the Company shall establish an external contact point handled by a legal office (hereinafter collectively referred to as the “Contact Points”).
(1)Internal contact points
Anicom Holdings, Inc.
Sumitomo Fudosan Shinjuku Grand Tower 39F
8-17-1, Nishi-Shinjuku, Shinjuku-ku, Tokyo, 160-0023, Japan
1)To the General Manager of the Compliance Promotion Department
2)To the internal legal counsel, Compliance Promotion Department
3)To the standing Audit & Supervisory Board Member
(2)External contact point
Yaesu Sogo Law Office
Room 1559, Yurakucho Denki Building South Tower 15F
1-7-1 Yurakucho, Chiyoda-ku, Tokyo, 100-0006, Japan
To the internal whistleblower contact point, Anicom Holdings, Inc.
2.The Contact Points shall, except where no means of contact has been available, promptly notify persons using the System of the receipt of their reports or consultations, and shall notify the relevant persons using the System of the planned response within 20 days of receiving reports or consultations.
Handling of Matters Reported
Article 5.
1.Matters reported to the Contact Points shall be shared only among a limited number of relevant persons and information shall be strictly managed. The matters shall be investigated as necessary unless there is a legitimate reason for not doing so, and the necessary steps taken based on the results of this investigation.
2.The Contact Points shall, except where no means of contact has been available, notify the relevant persons using the System of the results of investigations and the correctional measures and other steps taken, as necessary.
Protection of Users of the System
Article 6.
1.Officers and Employees, etc. shall not treat persons using the System unfavorably because they reported to or consulted the Contact Points.
2.Officers and Employees, etc. shall not seek to discover the identity of persons who report to or consult the Contact Points, or persons who cooperate with investigations into the relevant matters.
3.After investigations into the relevant matters are concluded, the Contact Points shall, except where no means of contact has been available, confirm with the relevant persons using the System whether they have experienced the unfavorable treatment prohibited under Paragraph 1 above.
Education
Article 7.
The Company, etc. shall implement regular education and training for all eligible users of the System, including the Representative Director, to facilitate the dissemination of knowledge of the Contact Points and the compliance with the Group Internal Whistleblowing System Operating Rules and understanding of the Whistleblower Protection Act.
Disciplinary Measures, etc.
Article 8.
Where, as a result of investigations, actions have come to light that clearly violate laws, regulations, or other rules, or the Group Internal Whistleblowing System Operating Rules, the Company, etc. shall enforce appropriate disciplinary and other measures based on the Employment Regulations and Rules on Rewards and Punishments of the Company, etc.
Revision and Abolition
Article 9.
This policy shall be revised or abolished by resolution of the Board of Directors with the consent of all Audit & Supervisory Board Members.