Our group will comply with the relevant laws and regulations of the countries and regions in which it operates and will never tolerate profit taking through illegal or improper means.
We believe that it is important to detect violations or possible violations of laws and ethics by our group companies and any of their executives and employees at an early stage, to prevent violations and spreading of damage thereof, and to promptly implement measures to prevent recurrence.
For this reason, we have established a whistle-blowing hotline "Roki Group Help-Counter"(hereinafter “Help-Counter”) as described below. Please do not hesitate to consult us about any wrongdoings involving our group companies and any of their executives or employees.
Users Available to the Help-Counter
All executives, employees (direct employees regardless of employment status) and temporary employees currently working for our group companies (hereinafter “Employees, etc.”).
Those who have been the above-mentioned Employees , etc. in the past and who have retired or terminated within one (1) year.
Subject of Reporting and Consultation
Violation of laws, ordinances, etc. stipulated by the governments of each country and local public body, and ethical or moral problems in society, as well as any violation of or possible violation of any rules or prohibited matters within the company can be the subject of report.
Examples of illegal/ improper activities
Acts that distort healthy market competition
Acts that restrict competition with competitors, such as bid rigging and cartels
Unreasonable demands on distributors and acts that unreasonably restrict transactions
Acts that damage the credibility or the reputation of competitors and business partners
Providing illegal bribes to public officials and customers' employees
Acts that adversely affect social order and security
Business relationships with and provision of benefits to antisocial organizations and individuals
Illicit exports of export restricted goods, etc.
Transactions that encourage child labor and forced labor
Acts to falsify product quality and standards
IImproper inspection, mixing of prohibited substances, or other actions that disguise quality or performance
Acts that mislead counterparties into believing that the terms and conditions of a transaction, such as the price, are favorable
Acts that may cause damage to the lives and bodies of consumers and employees, such as inadequate safety design and warning statements.
Acts that damage the assets and credibility of the company or other companies
Embezzlement, theft, kickback from business partners, etc.
Unauthorized access or disclosure of trade secrets and confidential information
Postings in SNS site that damage the honor or reputation of the company or its employees
Unauthorized reproduction of copyrighted material, downloading of pirated edition of contents, etc.
Acts that falsify the company's performance
Inflating sales through fictitious and cyclical transactions
Acts that harm the workplace environment or violate human rights
Sexual harassment, power harassment, maternity harassment, etc.
Discrimination based on nationality, religion, gender, beliefs, etc.
Flow of Reporting and Consultation
Operation policy of the Help-Counter
Upon receipt of a report or consultation, unless there is a justifiable reason, we will conduct the necessary investigation after obtaining the informant's consent to conduct the investigation. However, in the event the purpose of the report is in the public interest and the contents of the report are important or require immediate action as the company, we may confirm the facts without obtaining the approval of the person who made the report or consulted.
Within 20 days of the report, the Help-Counter will notify the informant of whether or not the internal investigation of the contents of the report has been conducted.
Outside Contact (i.e. assigned corporate lawyers) is set up for the purpose of ensuring that informants use the Help-Counter without being noticed by the company's officials. In principle, the Outside Contact does not conduct fact-finding investigations.
The privacy of informants shall be protected, and the facts of reporting or consultation and the contents thereof shall be kept confidential except when necessary for investigation.
No informants will be disadvantaged by reason of reporting or consulting except when such report or consultation is made for improper purposes. In the event that an informant is likely suffering a disadvantage such as retaliation, we will take measures to prevent such conduct by obtaining written pledges from interviewers on an individual basis.
We will notify the informant of the company's response to the results of the investigation and the details of corrective measures and disciplinary actions to the extent that there are no obstacles. Follow-up will be provided to ensure that reports and consultations are not being handled in a disadvantageous manner, as necessary, for the protection of informants even after the reports and consultations are completed.
We will not tolerate threats against informants to prevent reporting or consultation, retaliatory acts against reporting or consultation, or other acts that interfere with investigations with reporting or consultation.
In principle, please report or consult with us in real names. We will also accept anonymous reports and consultations, but it should be noted that in such cases, there are limitations to the investigation for confirming the facts and that we are unable to notify you of the above results.
Address of Contacts
Please note that we can only respond in English or Japanese.
6-20-12 Minami-Oi, Shinagawa-ku, Tokyo 140-0013 Japan
ROKI GROUP Co., Ltd.
Takafumi Fujii, Auditor, or
Masayuki Hioki, GM of Legal Department
Telephone reception time: Monday to Friday, 8:45 to 17:30 (JST excluding our days off)
※A telephone call may not be received immediately due to business circumstances.
Kojimachi Diamond Building, 4-1 Kojimachi, Chiyoda-ku, Tokyo 102-0083 Japan
MOMO-O, MATSUO & NAMBA
（MOMO-O, MATSUO & NAMBA）
Attorney, Koji Ohe, Yuta Taguchi
Telephone reception hours: Monday to Friday 10:00 to 17:30 (JST excluding national holidays)
※The person in charge may be absent.
（Precautions for reporting or consultation to the Outside Contact points）
In the event of reporting to or consultation with the Outside Contact points, please tell clearly that it is the report or consultation to "Help-Counter of the ROKI Group",
or state as such when reporting or consultation by fax or e-mail.