Compliance

Glory strives to foster awareness of compliance Group wide and conduct honest and fair business activities.

Glory views legal compliance as an important management issue, and therefore strives to maintain and improve our compliance framework. One measure taken in that regard is the establishment of the Compliance Committee.

The Compliance Committee, chaired by President and comprised of full-time directors, related department heads, and two outside experts (attorneys at law), deliberates on key compliance-related issues in Glory Group, and the outcome is reported to the Board of Directors.

The Chief Compliance Officer, appointed from among the officers in charge, takes the initiative in planning measures to enhance compliance and in engaging in employee education and awareness activities.

As a part of this, we conduct compliance awareness surveys on a regular basis, striving to improve the mindset of our employees.

The Glory Group has established a whistleblowing system to address violations of laws and regulations, including human rights infringements related to discrimination, harassment, working hours, occupational health and safety, as well as breaches of competition and antitrust laws and corrupt practices such as bribery. To ensure early detection and remediation of compliance issues, we provide the following reporting channels:
(1) Line manager in whistleblower’s organization
(2) The Compliance Committee Secretariat
(3) External consultation services (law firms)
(4) External consultations services (consulting firms)

These hotlines are intended for us to identify problems and take corrective actions at an early stage. Whistleblowers can report anonymously, and all information received through the hotlines is handled with strict confidentiality. We ensure that privacy of whistleblowers is fully protected and whistleblowers will not experience any retaliation or disadvantage as a result of their reporting.

In fiscal 2024, 16 cases were reported, for which we have conducted fact-finding studies and took necessary actions.

In addition to the whistleblowing system, we address day-to-day legal and/or compliance-related inquires or issues appropriately as soon as they are identified. To prevent similar issues from occurring, we regularly publish summaries on internal notice and provide compliance training for employees.

Money laundering is hiding the criminal origins of money or the proceeds of crime within legal businesses or business activities or using legitimate money to support terrorism. Most countries now have antimony laundering legislation which enables law enforcement agencies to trace and recover laundered money. Businesses may commit offences by using laundered money or concealing its nature or origin or tipping off the money launderer - i.e. disclosing anything likely to prejudice an investigation or prejudicing such investigation. In addition there are offences of failing to report a suspicion if there are reasonable grounds to know or suspect that a third party is laundering money through your organisation.

Glory has established the Glory Legal Code of Conduct governing the laws and codes of ethics that must be adhered to by all Glory Group officers, employees, and business partners, including distributors, both domestic and overseas.

The code was developed from a global perspective to accommodate the rapid expansion of our overseas business. We strive to improve employee awareness of compliance through the distribution of the "Compliance Handbook" and training for every Group employee. In addition, we strive to conduct honest and fair business practice worthy of the Glory brand and to maintain and ensure a high level of compliance and ethical standards. Additions and amendments to the code may be made after approval by the company’s directors.

In fiscal 2024, there were no violations of laws or regulations that had a significant impact on our business.

We have specified rules to prohibit bribery and prevent corruption in the Glory Legal Code of Conduct and endeavor to keep all domestic and overseas employees and business partners informed of them. We also conduct e-learning and other suitable means of education to prevent corrupt practices.

In fiscal 2024, there were no occurrences of corrupt practices, including bribery.

Glory Legal Code of Conduct（Bribery and Corruption, Money Laundering）

(ⅲ) Bribery and Corruption

GLORY takes a zero-tolerance approach to bribery and corruption (and requires its business partners to do so as well). GLORY is committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. GLORY upholds all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.

(ⅳ) Money Laundering

Money laundering is hiding the criminal origins of money or the proceeds of crime within legal businesses or business activities or using legitimate money to support terrorism. Most countries now have antimony laundering legislation which enables law enforcement agencies to trace and recover laundered money. Businesses may commit offences by using laundered money or concealing its nature or origin or tipping off the money launderer - i.e. disclosing anything likely to prejudice an investigation or prejudicing such investigation. In addition there are offences of failing to report a suspicion if there are reasonable grounds to know or suspect that a third party is laundering money through your organisation.

The Glory Group recognizes the importance of its responsibility to properly manage the personal information of stakeholders, including customers, business partners, and shareholders acquired through our business activities. We therefore ensure the proper management of personal information according to the Privacy Policy.

The Group designates October as Corporate Ethics Month each year and provides e-learning training to foster compliance awareness among all officers and employees, regardless of employment status, such as regular, fixed-term, special contract, part-time, temporary, or dispatched staff. For newly hired employees (including new graduates and mid-career recruits), we provide onboarding training covering fundamental aspects of laws, ethics, and internal regulations. Through programs such as new manager training, level-specific training and specialized courses, we aim to deepen employees’ understanding and ensure their full awareness of corporate ethics and applicable laws and regulations.

In Japan, we provide ongoing training on key compliance topics listed below, based on our corporate philosophy framework and the GLORY Group Code of Conduct:
− Respect for human rights (e.g., prohibition of harassment)
− Financial regulations (e.g., insider trading prevention)
− Information management (e.g., information security)
− Personal data handling and social media use
− Transaction-related laws (e.g., the Antimonopoly Act and the Subcontract Act)
− Labor management
− Compliance-related guidelines
− Internal reporting system

Overseas, we also provide e-learning compliance training in 11 languages, across regions where the Group operates including Europe, the Americas, China, and Southeast Asia. The training emphasizes the GLORY Group Code of Conduct and covers key areas such as competition laws and trade regulations, prevention of bribery, corruption, and money laundering, as well as data security measures, including protection of personal and confidential information safeguards against unauthorized access.