Compliance Initiatives
Basic Compliance Policy
We have stipulated our basic compliance policy based on our Company Motto of “Courage, Courtesy, and Justice,” with the strong conviction that “adherence to laws and ethics are the engine of sustainable growth for our company.” Furthermore, we printed the basic compliance policy on compliance cards, which we recommend all employees carry so that they can review the compliance policy at any time.
Compliance Promotion System
In 2009, we established the Compliance Committee with the aim of providing support and guidance, and ensuring that compliance is practiced by Group officers and employees. To provide a third-party perspective, we appoint someone from outside the company to chair the Committee, who attends meetings of the Board of Directors to raise issues and make recommendations. The committee meets once a month to address compliance-related issues, as well as implement and provide guidance on compliance training.
The Compliance Promotion Department takes the initiative in promoting compliance, and the heads of each division at the Head Office, the general managers at each regional headquarters, and the presidents of affiliated companies have been appointed as the persons in charge of compliance and handle reports under the Compliance Promotion Department, while we are working to publicize and raise awareness about compliance through training, etc. In addition, as the secretariat of the Compliance Committee, it plays a role in educating officers and employees about the activities of the Committee.
Awareness Surveys
The Company conducts awareness surveys on a continuing basis to confirm employees’ compliance awareness and issues, and to verify the effects of compliance-related initiatives in order to make improvements. In this survey, we have set an evaluation score of 1.0, requiring 80% or more affirmative answers, as our benchmark. Particular weight is given to setting medium- and long-term goals and making systematic efforts to achieve them.
| 2011 | 2015 | 2017 | 2019 | 2021 | FY2023 target | |
|---|---|---|---|---|---|---|
| Overall evaluation | 1.09 | 1.15 | 1.25 | 1.27 | 1.30 | 1.35 or above |
| Awareness of the hotline | 0.59 | 0.79 | 0.97 | 1.15 | 1.00 | 1.10 or above |
Practical Manual for Compliance
We have compiled and are implementing a Practical Manual for Compliance that presents legal and ethical problems that employees could potentially face in practice. In addition, we have compiled a Practical Manual for International Compliance to serve as a reference point when dealing with issues in other countries, where different laws and customs apply. This version is used at our overseas offices.
Compliance Training
We carry out on-going career-level-specific training and e-learning to improve compliance awareness, eliminate harassment, and boost understanding and dissemination of the whistleblowing system. In FY2021, we conducted training based on events that have occurred in recent years for managers at construction sites nationwide and in sales departments at each regional headquarters.
| Training Program(FY2021) | Participants |
|---|---|
| Training for Company Officers and Senior Management at Head Office, Regional Headquarters and Branch Office (October) | 827 |
| Training for New Hires and Newly Appointed Company Officers (April$2013 November) |
277 |
| Training for Managers at Construction sites (July- November) | 362 |
| Training for in Sales (July$2013 August) | 62 |
| Training for Branch workers and Temporary workers (March) | 721 |
| E-training (July$2013March) | Average participation rate: 59.7% |
Whistleblowing System and External
Consultation Hotline We have established the Nishimatsu Hotline internal reporting system to improve our corporate culture and deter misconduct, and the Workplace Hotline that enables employees to contact an external professional organization regarding human relations in the workplace or mental health issues.
| Fiscal 2017 | Fiscal 2018 | Fiscal 2019 | Fiscal 2020 | Fiscal 2021 | |
|---|---|---|---|---|---|
| Nishimatsu Hotline | 29 | 20 | 30 | 33 | 28 |
| Workplace Hotline | 23 | 21 | 16 | 12 | 12 |
Web Risk Monitoring
Since fiscal 2016, we have contracted with an outside firm to collect information related to the Company that is posted in social media such as Twitter, Facebook and online message boards. The collected information is checked and analyzed daily.