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 consisting of internal Board members, 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.
We conduct compliance awareness survey for employees on a regular basis. In fiscal 2021, we verified and analyzed the results, provided feedback to each department, and implemented countermeasures where necessary.
Glory has set up four compliance helplines advised by (1) one's direct supervisor, (2) the Compliance Committee office, (3) a workplace consultant, and (4) external lawyers to deal with overall compliance issues of the Glory Group. The helplines aid in detecting and addressing issues at an early stage, while protecting those seeking consultation under the Internal Regulations on Consultation.
In fiscal 2021, 28 cases were received through the helplines and efficiently handled. The number of consultations increased compared with the previous fiscal year as a result of survey follow-ups (fiscal 2020 compliance awareness surveys) while the establishment of a temporary consultation desk during the fiscal 2021 Corporate Ethics Month has also contributed to this increase.
In addition to our compliance helplines, we also handle problems related to day-to-day legal and compliance consultations and issues. Furthermore, we make efforts to prevent recurrence by coordinating with related departments, in such ways as sharing problems in internal bulletins and training activities, with the aim of avoiding future issues.
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 2021, Glory discovered an incident of embezzlement by a former employee of its domestic consolidated subsidiary. We immediately established an internal investigation committee, chaired by the company’s director (chairman of its Audit & Supervisory Committee) to investigate the facts and causes of the incident with the assistance of external attorneys and CPAs. We take the outcomes of the investigations seriously and are committed to taking necessary preventive measures based on the proposals made in the committee’s investigation report.
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 2021, there were no occurrences of corrupt practices, including bribery.
(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.
Also, alongside the enforcement of the Amended Act on the Protection of Personal Information in April 2022, we are implementing initiatives such as maintenance regulations and carrying out training sessions to related departments to ensure proper handling.
We conduct comprehensive training, including at Group companies, to ensure thorough compliance. New employee education includes learning about fundamental legal and ethical issues as well as internal rules. In addition, we conduct e-learning every year during Corporate Ethics Month in October for all domestic group employees to refresh their understanding of basic issues and social trends.
In fiscal 2021, we conducted programs in areas such as the rules of confidential information protection and harassment as stipulated in the Glory Legal Code of Conduct, with a combined total of 6,810 employees taking part in the various programs. Other programs include newly appointed manager training and specialized training to develop a more thorough and precise understanding of issues concerning laws and corporate ethics.