Compliance

Compliance

dip has posted the Basic Policy on Compliance on its internal bulletin board and familiarized employees with this policy through training. 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 compliance training for new employees and new managers, in order to raise awareness of compliance according to the attributes of the attendees. We have a whistleblowing system in which all employees are given a card containing contact information for reporting and are thoroughly informed of the process. 

The Board of Corporate Auditors receives regular reports on the status of whistleblowing and consultations, and after reporting to the CEO, COO, CBO, or General Manager, steps are taken to confirm the facts and improve the situation, while ensuring that the whistleblower does not suffer any disadvantageous treatment. 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 Promotion System

For the purpose of improving compliance, the Company has established the Compliance Promotion Council, chaired by the COO and composed of all executive officers.

The Compliance Promotion Council meets to discuss compliance-related matters four times a year and reports to the Board of Directors. Based on the reports of the Compliance Promotion Council, the Board of Directors recognizes and examines the overall picture of compliance violations and decides on measures to prevent recurrence.


Compliance training

We conduct information security training and drills appropriate to the scope of work and position.

Entry level training

We conduct ISMS/PMS training for all new employees, including temporary and part-time workers, to allow them to acquire the knowledge and understanding of measures related to information security and privacy, as well as our internal information security rules.

Training for new graduates

We have a program for new graduates, several hundred of whom are hired each year, to acquire basic knowledge and understanding of measures related to information security and privacy, as well as our internal information security rules, within the new graduate induction training.

Training for New Management

When appointed to a managerial position, we provide training to acquire the security-related knowledge necessary for organizational management.

Compliance Training

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., in order to raise compliance awareness. Other issues related to bribery prevention and human rights are incorporated as appropriate. 


FY'21/2
FY'22/2
FY'23/2
Compliance verification test participation rate
100%100%
100%


Data on Compliance

(Number of cases)


FY'20/2
FY'21/2
FY'22/2
FY'23/2
Whistleblowing cases
1
3
1

Violation of code of conduct
Fraudulent acceptance of orders
0
0
1
1
 (Subject to disciplinary action)
0
0
1
1
Unauthorized use of expenses and goods
1
1
0
0
 (Subject to disciplinary action)
1
1
0
0
Underreporting of work hours
0
1
0
0
 (Subject to disciplinary action)
0
1
0
0
Breach of anti-bribery policy
-
-
-
0
 (Subject to disciplinary action)
-
-
-
0
Other
0
1
0
1
 (Subject to disciplinary action)
0
1
0
1
Security breach
1
0
3
11
 (Subject to disciplinary action)
0
0
0
0

Number of reports to Personal Information Protection Commission
-
-
-
0
Number of reports to JIPDEC
* Excluding the number of reports to
   the Personal Information Protection Commission

-
-
1
8
Other
-
-
2
3
Human rights violation, harassment
Number of harassment-related counseling
5
3
0
15
    (Subject to disciplinary action)
1
0
0
3
Other
0
0
0
0
    (Subject to disciplinary action)
0
0
0
0

* Beginning with the fiscal year ended February 28, 2022, a breakdown of the number of security breaches is shown.


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 internal rules, laws, regulations (including any act that could potentially lead to such an occurrence), 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".

To familiarize employees with the system, we have provided every employee with a card that contains contact points.And inform them of the whistleblowing system system at the compliance verification test for all employees held once a quarter.

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 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.
No consultant or whistleblower shall receive any disadvantageous treatment for making a report or consultation.

Person who can report and consult

・Executives or employees of Group companies (including those who have retired within the previous year)

・Business partners of our Group or their executives or employees (including those who have retired within the previous 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.

Contact:Nakamura Law Office TEL+81-3-6821-1255

(Male)Yuta Machida
Mail:y.machida@nakalaw.jp TEL+81-50-5526-2541(Direct line)

(Female)Yuka Saito
Mail:y.saito@nakalaw.jp TEL+81-50-5526-3607(Direct line)

(English only contact)Yuki Nakamura
Mail:nakamura@nakalaw.jp TEL+81-50-5526-1968 (Direct line)

*By phone, please contact us between 10:00 and 18:00 on weekdays.
*By email, we are available 24 hours a day, 365 days a year (response hours are the same as for phone calls)

Whistleblowing system