Compliance

Basic Concept

GOLDWIN Group aims to be corporate group trusted by its stakeholders that fulfills its social responsibilities by conducting business activities in a sincere and fair manner while complying with laws and regulations and adhering to social standards and ethics. To realize this, we recognize that it is essential for each employee to act with a strong awareness of compliance.
We foster a corporate culture that does not permit fraud, by establishing the Corporate Code of Conduct and Employees’ Code of Conduct, both of which serve as the standards for employees to choose the appropriate action, ensuring that all employees are familiar with these standards.

Promotion Framework

We have built a compliance framework led by the Compliance Department. Compliance activities are reported to the ESG Management Committee, with oversight and guidance from the Board of Directors. The Internal Audit Office cooperates in operating the internal whistleblowing system and in activities to raise employee awareness. The Information Security Committee (Information Technology Department), HR, General Affairs and Legal Departments cooperate in planning and conducting training, and in confirming and complying with laws and regulations.

Framework

Compliance Promotion

GOLDWIN and Group companies follow our internal whistleblowing system and ensure that external directors and auditors can express independent and objective opinions at Board of Directors and Board of Auditors meetings. We thereby ensure that directors and auditors perform their duties lawfully. We provide training to ensure that all employees fully understand relevant laws, our corporate philosophy, and our code of conduct. We also confirm compliance with business procedures and manuals at all locations through internal audits and control system assessments. We also conduct annual compliance workshops.
We distribute the Compliance Card, a guide to the internal whistleblowing system, code of conduct and standards of conduct, to all employees and instruct them to carry it always. We also strive in other ways to raise employee awareness of compliance issues.
In FY 2022, we conducted a compliance awareness survey on 1,664 people with a GOLDWIN Group email address. We have reflected the results of their responses in compliance training and other measures related to thorough compliance awareness to help foster an awareness for compliance. We also conducted a self-check survey on sales associates which included questions on compliance, and responses were received from 822 of them. Their responses showed that they are highly aware of compliance and have a deeper understanding of it. Through these activities, we will continue to keep track of compliance awareness among employees, and link the findings to training and measures.

Compliance Education

We conduct annual compliance workshops for all employees, including those at Group companies. In FY 2022, we held workshops for 2,810 employees (100% attendance) with the objective of promoting understanding and awareness of compliance and risk management, and familiarizing employees with our internal whistleblowing system.
We also published 12 issues of Compliance News, our e-newsletter that encourages employees to think about compliance in terms of themes that are familiar to them, including: Be careful of insider trading! What is maternity and paternity discrimination? What not to do or say that hurts LGBTQ+ people.
We also send sales associates a compliance newsletter by mail to share our approach to compliance and to nurture awareness among all employees. In FY 2022, we again shared the results of our internal audit and the increase in compliance awareness among employees, and once again requested and supported compliance promotion at each store.

Internal Whistleblowing System

GOLDWIN Group deploys an internal whistleblowing system (corporate ethics hotline) for queries and reports on misconduct, violations of the law and corporate ethics, or any possible violation in execution of company business.
Queries and reports can be made anonymously, either to an internal contact desk or externally to a lawyer or a labor and social security attorney’s office. We conduct thorough investigations and reviews based on the content of the reports or queries, respond to the person who raised the issue, and take action accordingly. Personal information is protected and kept confidential in accordance with the Whistleblower Protection Act, so that no one suffers any consequences in raising a query.
In FY 2022, we revised our Whistleblower Protection Regulations in accordance with the June 2022 revisions of the Whistleblower Protection Act, and worked to strengthen awareness of our internal whistleblowing system and the contact points. We received a total of 44 consultations and reports in the four categories of suspected compliance violation, suspected harassment, personal relations in the workplace, and other, all of which have been dealt with appropriately.

Internal whistleblowing system mechanism

Future Issues

We will continue to comply with laws and regulations, to observe social norms and ethics, and to meet societal expectations. To this end, we will share information about relevant laws, our corporate philosophy, and our code of conduct, conduct internal audits and internal control system assessments, operate our internal whistleblowing system, take rigorous efforts to prevent corruption, hold compliance training, and strive to foster compliance awareness among all employees.