Governance

Initiatives

Introduction of Initiatives

Anti-corruption training

The BREXA Group emphasizes the establishment and operation of a legal compliance system as stated in the BREXA Group Code of Corporate Ethics and Conduct and the global governance policy, and as part of those efforts, focuses on preventing corruption. To ensure compliance, in addition to appropriate management in accordance with anticorruption regulations for subsidiaries and associates to prohibit all forms of bribery and other types of corruption, the Group has also established a system for continually conducting employee training using e-learning, etc.

Overseas whistle-blowing systems

The Company led the industry in introducing an internal reporting system as a whistle blowing system in 2008 for all employees, including contract workers and dispatched employees, that was outsourced to a neutral third party, a specialist in human resources and labor law. By responding appropriately at an early stage in the event of a violation of law, misconduct, unethical behavior, socially unacceptable behavior, etc., while systematically ensuring the protection of whistleblowers, the Group has established risk management in business operations and a more robust legal compliance system.
Together with its global expansion, the Group expanded the scope of the internal reporting system as the common whistleblowing system used worldwide, and the system supports reporting using a wide range of means, such as telephone calls, short message services, e-mails, letters, etc. in the local language, English and Japanese. In Central and South America, to build a scheme targeting not only Group company employees, but also customers, suppliers and contractors, the Group is working with OSI SOUTH AMERICA HOLDINGS SpA (OSSA) to select partners and build a system for this project. Moreover, in Europe where there are historical backgrounds to whistle-blowing systems, such systems are put in place in line with each country’s laws, and currently in the Group, OTTO, Liberata, CDER, and CPL have their own internal systems. Moreover, Orizon also plans to formulate and introduce a system in line with the “EU Directive” on the protection of persons who report breaches of Union law.
Recently, in April 2021, the Company held a webinar for global training on the internal reporting system with an attorney-at-law.
The webinar provided an opportunity to re-educate the participants about overviews of the internal reporting system and the common whistle-blowing system used worldwide, examples of violations of laws and regulations in each country, a wide range of case studies, etc.

Compliance

Publication of compliance articles in group newsletters “Ratoon”

Creation of compliance guidebooks and compliance training

Although compliance is important, employees are of the impression that it is somewhat abstract and find it difficult to imagine specific compliance-related actions. In June 2022, the Companyʼs General Affairs Department prepared a compliance guidebook and compliance violation case studies given this situation, and accordingly released and distributed it in e-text format to officers and employees of the Company and Group companies in Japan.
In addition, we have set the stage prior to establishing the compliance training system under development. In early March 2022, we implemented training for directors of the Company and Group companies in Japan, then beginning in May 2022, we have been successively providing other officers and employees with various forms of compliance training based on the training system. Considering the nature of this training, it is likely that we will call on expert lecturers including certified public accountants, attorneys at law, and university professors of law to cover topics related to internal controls and accounting.

Internal control system training (Japan)

The Group has prepared a number of e-learning training courses regarding compliance for all in-house employees including dispatched employees in Japan. The online training related to internal control was expanded in April 2021 based on the belief that strengthening “internal control” is essential to prevent human errors and misconduct and achieve growth of the Company.
The training includes a lineup of 15 different contents, ranging from an introductory explanation of internal control for beginners to advanced courses on internal control reports, etc. for employees engaged in this type of work, allowing participants to gain a deeper understanding of the necessity and importance of internal control.
Furthermore, for employees who have completed the e-learning, additional training is provided through interactive participation in online meetings with an instructor that include explanations of key points in the e-learning videos, case studies, and question and answer sessions. This training boasts a satisfaction rate of 100% among participants.