| 1. |
Appointing a Chief Compliance Officer and Establishing the Legal Compliance Committee
To begin anew as a responsible corporate citizen, ISK will reinforce
its legal compliance based on the philosophy of its Code of
Conduct. As an officer responsible for group-wide legal compliance,
ISK's Board of Directors has appointed a Chief Compliance Officer
(CCO). To ensure that management places the utmost priority
on legal compliance, ISK has also established a Legal Compliance
Committee, chaired by the CCO and comprising outside lawyer(s),
auditor(s) and directors of individual divisions.
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| 2. |
Reinforcing the Whistleblower System
To detect risks involved in corporate activities and to prevent
compliance-related problems at the earliest possible stage,
ISK will reinforce its whistleblower system. To encourage employees
to report any problem involving violation or possible violation
of laws, regulations or social norms, ISK has established a
hotline to an outside lawyer, in addition to the existing whistleblower
system (which reports to the office of the Compliance Committee).
The new hotline is designed to facilitate whistleblowing as
soon as employees find any problem, even if they find it difficult
to report to their superiors or using any existing system.
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| 3. |
Establishing the Internal Audit Office
Directly under the President, ISK has established the Internal
Audit Office, an organization independent from other organizations
dedicated to business operations. By conducting internal audits,
the Internal Audit Office will confirm the reliability of ISK’s
financial statements, and review the scope of responsibilities
borne by individual staff members in daily business operations,
together with reporting systems and business procedures, so
as to evaluate our business efficiency and prevent errors and
unjust actions, thereby improving overall business performance.
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| 4. |
Redress for Violations |
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| 1) |
If any member violates any laws, regulations
or social norms, or is suspected of violating them, the
Internal Audit Office will immediately begin an investigation
and report the results to the Compliance Committee, which
will decide the appropriate measures to take. |
| 2) |
To prevent recurrence of similar violations,
the CCO will propose, as soon as such problems are found,
remedies and measures to prevent recurrence.
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