Compliance

Basic Policy

The Alps Alpine Group has established The Alps Alpine Group Code of Conduct (hereafter, “the Group Code of Conduct”) as a basic policy on compliance-related matters, based on its management stance set forth in its Corporate Vision. We make an effort at all times to act responsibly and sensibly, aiming for fair management. Following this Code of Conduct, we believe it is important to independently and proactively take appropriate action. To this end, we make regular efforts to spread awareness of and educate stakeholders about the Code.

The Alps Alpine Group Code of Conduct

System for Promoting Compliance

At the Alps Alpine Group, internal controls are established to ensure that management of Company and Group operations is carried out appropriately. We have put in place a Companywide management structure with the president & CEO as the chief officer in charge. In regard to the management and use of grants and subsidies received from public agencies in Japan, within each headquarters, compliance promotion officers and promoters ensure that grants and subsidies are managed and used within the organization according to the regulations. As self-evaluations, each compliance promotion representative also regularly monitors the use of grants and subsidies within his or her headquarters and reports to the supervising officer and the internal audit department. In addition, the internal audit department regularly monitors the use of grants and subsidies Companywide and reports to the chief officer in charge, as well as to the Board of Directors.
To ensure early discovery and correction of misconduct or other compliance incidents, the persons in charge of facilities in Japan and at overseas affiliates are obliged to report any incidents when they occur to relevant Alps Alpine vice presidents and the compliance department. Important compliance-related matters are reported to the Board of Directors.

Whistleblowing System

The Alps Alpine Group strives to identify issues and potential risks within the organization or related to business activities at an early stage to prevent their occurrence and minimize impact. As part of these efforts, we have implemented a whistleblowing system.
The whistleblowing system is a component of our corporate governance framework, aiming to prevent, quickly detect, and correct misconduct, fraud, and violations of laws or internal rules, thereby realizing our management approach of “fair management.” The Company and its major domestic and international Group companies have established internal reporting hotlines independent of the management. Ideally, compliance violations should be addressed and resolved within the workplace or operational lines, but the hotline exists as a safeguard for situations where this is difficult.
We have established an internal Ethics Hotline at the Company and Group companies to receive reports or consultations from those working at the Company or Group in Japan (including executives, employees, temporary and contract workers, and sole proprietors), as well as individuals within one year of leaving. Whistleblowers can report or consult using their real names or anonymously. Multiple reporting channels are available, including telephone, email, and written correspondence. The hotline is governed by the Ethics Hotline regulations in accordance with Japan’s Whistleblower Protection Act, strictly ensuring anonymity and protecting whistleblowers from any unfair treatment or disadvantage due to their reports. If any breach of confidentiality or unfair treatment occurs, remedial action will be taken to restore the whistleblower’s position, and disciplinary measures will be imposed in accordance with internal rules. In conducting fact- finding investigations, we pay close attention to maintaining confidentiality and anonymity. If a report is found to be valid, appropriate action is taken.
Overseas subsidiaries have also established internal whistleblowing systems, with local representatives, legal, or administrative departments designated as contact points to receive complaints or reports from employees. Each overseas subsidiary also designs and operates its system in compliance with the whistle-blower protection laws of the respective countries.
Additionally, to establish a reporting channel for a broader range of stakeholders, we joined the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER^*) in April 2023. We will listen to submitted feedback and advice and promote stronger compliance through collaboration with JaCER and other support organizations.
Contact information for the whistleblowing hotlines of the Company and each Group company is regularly communicated via the internal portal, posters, and various training programs.
In FY2024, the Ethics Hotline received 32 reports. The status of the whistleblowing system, including the number of reports and summary of content, is regularly reported to the Board of Directors and the Audit and Supervisory Committee, without disclosing the identity of whistleblowers.

Japan Center for Engagement and Remedy on Business and Human Rights (JaCER)

Form

Monitoring of Ethical Standards

At Alps Alpine, a self-evaluation is held once a year and an internal audit is conducted once every three years, in principle, on ethical standards in each department and subsidiary, including overseas affiliates, in order to strengthen internal control functions. The audits are held in accordance with the Group Code of Conduct to confirm the level of awareness of employees in regard to the Code of Conduct and the degree of receipt of compliance and CSR training throughout the Group, as well as the status of compliance with anti-corruption and bribery policies.

Anti-corruption Initiatives

The Group Code of Conduct defines the scope of the giving and receiving of gifts among clients, business partners, and public officials, as well as the prevention of corruption and bribery, including the prohibition of conflicts of interest, embezzlement, and misappropriation. Through compliance and CSR training, the Company continues to educate and raise awareness among stakeholders regarding the prevention of corruption and bribery.
Moreover, because they are considered compliance violations, if the matter is determined to be factual, the appropriate actions will be taken while examining and conducting the measures necessary to prevent recurrence and subsequently reporting the details to the Board of Directors. Employees who engage in acts of corruption will be subject to disciplinary actions based on internal regulations.

Training on the GROUP CODE OF CONDUCT

To improve understanding and awareness of the GROUP CODE OF CONDUCT, training sessions are held annually at domestic and overseas offices and subsidiaries, including overseas affiliates.
Through this training and other means, we continue to educate our employees to raise awareness about anti-corruption and the prohibition of bribery.

• Corporate Governance
• Compliance
• Risk Management
• Tax Management
• Information Security