Basic Policy on Compliance

The Company has established the Basic Policy on Compliance to ensure that Board Directors and employees adhere to laws, regulations, and the Articles of Incorporation, fulfill their social responsibility, and respect corporate ethics in the execution of their duties. dip also conducts training through e-learning five times per year for all employees regarding information management, labor legislation, and other compliance matters, as well as in-house lectures for Directors and Audit and Supervisory Committee Members and compliance training for new employees and new managers, in order to raise awareness of compliance as it pertains to the respective duties of the participants. .

The Audit & Supervisory Committee Members and Internal Audit and Control Office work together to audit the status of the compliance system based on the annual plan and report to the Board of Directors quarterly.

Compliance and Risk Management System

To enhance compline and risk management, the Company has newly created a Compliance and Risk Management Promotion Council, which is chaired by the Representative Director and COO and consists of all Executive Officers. The Council meets four times a year to present and discuss matters related to compliance and risk management, and reports the results to the Board of Directors.

Based on reports from the Council, the Board of Directors obtains and examines an overview of compliance violations and company-wide risks, and decides what actions to take to prevent recurrence.

Furthermore, the Governance Promotion Department of the Corporate Management Control Division of the Corporate Management Headquarters has been designated as the department in charge of compliance/risk management and is working to maintain and improve the compliance/risk management system. In the event of a compliance/risk management problem, we have established and are operating a system that ensures it is promptly reported to executive directors and executive officers. In addition, the department is the designated secretariat for the Compliance/Risk Management Promotion Conference.

The Company also has a system in place where, should a serious incident affecting business activities occur, we set up an emergency response team headed by the CEO to quickly and accurately address the situation and keep losses and damage to a minimum.

Compliance training

In order to raise compliance awareness, we conduct a quarterly compliance verification test for all employees. The test covers issues related to general compliance, knowledge of information security, our regulations and policies, reporting systems, etc. . Other issues related to bribery prevention and human rights are incorporated as appropriate.

Furthermore, we work to raise compliance awareness according to the specific duties and responsibilities of individual employees. To that end, we provide internal workshops for Board Directors and Board Directors who are Audit and Supervisory Committee Members, compliance training for new employees and new managers, and thematic training for all employees (LGBTQ training in FY’24/2).

Whistleblowing system and Compliance Consultation Hotline

Companies within our Group conduct business activities based on legal compliance and high ethical standards for the benefit of various stakeholders. In the unlikely event that an act that violates or could potentially lead to a violation of internal rules, laws, regulations, or any act that is inappropriate based on social norms occurs within the organization, we will promptly correct it and take measures to prevent recurrence. Toward this end we have established an independent "whistleblowing system and Compliance Consultation Hotline".

This contact point is for officers, employees, and business associates of our Group to report and consult when any of the above-mentioned acts occur within the Group. Information that can identify an individual is strictly protected and managed in consideration of the privacy of the whistleblower/consulter. In cases where communication or reporting to the relevant departments within the Group based on the whistleblowing system is necessary, personally identifiable information shall not, in principle, be disclosed without the consent of the person reporting or consulting, unless there is a justifiable reason. Furthermore, the informant shall not be subject to any disciplinary punishment, discriminatory or other retaliatory action, adverse effect on personnel evaluation, harassment or any other prejudicial treatment as a result of the informant's report or other action.

To familiarize employees with the system, we have provided every employee with a card that contains contact points. Employees are also reminded of the whistleblowing system at the compliance verification test held once a quarter.

Person who can report and consult

We accept submissions and consultations from a wide range of officers, full-time employees, contract employees, part-time employees, temporary employees, business partners, etc. of the Group (including those who have retired within one year).

Conduct subject to reporting and consultation

・Actions in violation of laws and regulations pertaining to our Group and its related parties
・Actions in violation of internal rules and regulations
・Actions which are socially unacceptable
・Actions that may lead to any of the above

How to report or consult

・We accept reports and consultations by email or telephone. It is also possible to report and consult anonymously.
・If the content of the report or consultation is abstract or unclear, it may be difficult to investigate. When making a report or consultation, please be as detailed as possible (when, where, who, what, and how).
・Please note that we cannot accept reports or consultations for the purpose of gaining an unfair advantage, inflicting damage on others, or for any other wrongful purpose.

Whistleblowing system

Data on Compliance

*4　End of February
*5　dip has transitioned from a company with an Audit & Supervisory Board to a company with an Audit & Supervisory Committee with the resolution of the 26th Annual General Meeting of Shareholders held on May 24, 2023.