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

Compliance Framework

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

The Committee is chaired by President and consists of internal Board members, related department heads, and two outside experts (attorneys at law), and deliberates key compliance-related issues in Glory Group. Results of these deliberations are reported to the Board of Directors.

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

The Company conducts surveys on employee satisfaction and compliance awareness of our employees on a regular basis. In fiscal 2020, as our working environment has changed due to the COVID-19 pandemic, we conducted additional survey focusing on changes in work style. Based on the results of these surveys, we work to create better environment by taking specific measures for the various issues raised by the employees.

By implementing these measures, the Company will continue to make efforts to improve compliance awareness.

Compliance Framework

Compliance Framework

Whistleblowing System

Glory has set up four compliance helplines advised by (1) a Departmental compliance Manager, (2) the Compliance Committee secretariat, (3) an office consultant, and (4) an external helpline (law firm) as a consultation service (helpline) for overall compliance issues of the Glory Group. The helplines were established to detect and correct issues at an early stage as well as to protect those seeking consultation under the Internal Regulations on Consultation.

From fiscal 2019, we expanded the service to include domestic group companies, and from fiscal 2021, overseas subsidiaries will also be able to make use of the service.

In fiscal 2020, 16 cases were received through the whistleblowing system and properly handled based on factual investigations.

Whistleblowing Flow

Whistleblowing Flow

Legal Code of Conduct

We 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 activities such as the distribution of the "Handbook" and training for every Group employee in order to continue to conduct honest and fair business worthy of the Glory brand and to maintain and ensure a high level of compliance and ethical standards. Moreover, additions and amendments to the code may be made after approval by the directors.

In fiscal 2020, there were no violations of laws or regulations that had a significant impact on our business.

Corruption Prevention

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 2020, 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.

Personal Information Protection

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.

Furthermore, we have developed internal rules and conducted training to respond effectively to the EU General Data Protection Regulation (GDPR), which went into effect in May 2018.


Compliance Education

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 2020, 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 6,857 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.

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