Basic Approach to Compliance

 The Alps Alpine Group Code of Ethics is a statement on how employees of the Group across the world are to conduct themselves in order to actualize shared values embodied in the Corporate Philosophy and Management Approach.
 We appeal to all organizations and employees within the Alps Alpine Group to make sure they act responsibly and sensibly at all times in line with the Alps Alpine Code of Ethics. Our aim is fair management in keeping with the purpose of the law, social requirements and corporate ethical standards. In this regard, we believe it is important to go beyond the formalities of observing laws and rules and take appropriate action proactively having acquired an understanding of why those laws and rules are necessary – their purpose and significance.

Alps Alpine Group Code of Ethics [PDF]

Implementation of Compliance Measures

 To ensure that company management and Group operations are carried out appropriately in line with the Alps Alpine Group Code of Ethics, Alps Alpine establishes and implements internal controls, departments conduct self-evaluations (monitoring) of their own activities, and the internal audit department performs internal audits of the activities and operations of departments and subsidiaries, including overseas affiliates.
 For example, in Japan, grants and subsidies received from public agencies are managed and used according to a specific set of in-house regulations, and we have in place a companywide management structure with the president and CEO as the chief officer in charge and the managing vice presidents as the supervising officer. Within each headquarters, where there are structures in place for promoting compliance, the compliance promotion representative for the headquarters – the head of the planning department – assigns compliance promotion officers who ensure that grants and subsidies are managed and used within the organization according to the regulations. Each compliance promotion representative also regularly checks up on the use of grants and subsidies within their headquarters and reports to the supervising officer and the internal audit department. The internal audit department regularly checks up on the use of grants and subsidies companywide and reports to the supervising officer and the chief officer in charge.
 To ensure early discovery and correction of misconduct or other compliance incidents, persons in charge of facilities in Japan and overseas affiliates are obliged to report any incidents when they occur to the relevant Alps Alpine vice presidents and the managing vice presidents as well as to corporate planning and compliance departments.

Tax Policy

 In keeping with the Founding Spirit (Alps Precepts) and Corporate Philosophy – Alps Alpine innovates value for humans and society on a brighter planet – we at Alps Alpine will always “act fairly and with integrity as global players.” We take full advantage of our close Group ties and integrated capabilities, while respecting the independence and autonomy of group companies, to rigorously enforce compliance, making sure that all employees comply with laws and in-house regulations, respect social norms and act in line with good corporate ethics.
 In the case of taxes, our basic policy is to fulfill our societal obligation to properly pay all taxes due in accordance with local tax laws, through communication with tax authorities, and to not utilize corporations or undertake measures for the principal purpose of reducing tax liabilities.

  1. Tax Governance
     Responsibility for Alps Alpine’s tax governance lies with the vice president in charge of accounting. Practical tasks are performed by the tax departments, which manage and report on tax matters. The vice president in charge of accounting routinely reports on payment of both domestic and foreign corporate taxes to the Board of Directors along with case-by-case reports on individual tax matters, such as tax audits. Outside specialists are engaged for matters of a highly technical nature, including tax audits relating to transfer pricing.
  2. Tax Planning
     With its global operations expanding, Alps Alpine makes effective use of favorable tax systems in countries around the world in order to maximize value for shareholders. However, we do not engage in tax avoidance that might deviate from the purpose of the law.
  3. Tax Risks
     While decisions on tax matters are made taking into consideration the significance of tax risks and/or tax benefits, there are no set quantitative criteria for determining significance. Decision-making follows a conservative approach with significance judged on a case-by-case basis.
  4. Tax Monitoring
     Vice presidents in charge of accounting and tax affairs continually monitor our tax position in each country based on regular reporting from subsidiaries in those countries regarding the completion of tax returns, for example. We also make sure we are able to address any additional tax issues arising as a result of tax audits or tax reform by obtaining information from subsidiaries as required.
     Matters relating to transfer pricing systems and other complex tax issues arising in each country are addressed with support from tax firms or other outside experts.

Global Implementation of Compliance and CSR Training

 To improve understanding and awareness regarding compliance and CSR, Alps Alpine regularly implements compliance and CSR training.
 The training, based on the Alps Alpine Group Compliance Charter, begins with a message from Alps Alpine’s senior management, the president and CEO. As well as providing an overview of compliance and CSR concepts, the training covers such topics as proper accounting procedures, information security, prohibition of harassment and discrimination, compliance with antitrust law, and prohibition of corruption and bribery.
 In fiscal 2019, the training curriculum was as follows.

Fiscal 2019 Compliance and CSR Training Curriculum

  1. Message from the President & CEO
  2. Insistence on quality
  3. Prevention of harassment, discrimination, abuse and forced labor
  4. Proper accounting
  1. Crisis management
  2. Embezzlement, misappropriation, entertainment and gifts
  3. Competition/antitrust law (with a focus on cartel regulations)
  4. Whistleblowing system

Anti-corruption Measures

 The Alps Alpine Group Code of Ethics defines the scope of giving and receiving of entertainment or gifts among clients, business partners and public officials and prohibits conflicts of interest, embezzlement and misappropriation. Ongoing education, including in the form of compliance and CSR training, is provided to remind and warn employees about prohibition of embezzlement and misappropriation and restrictions on entertainment and gifts.
 The types of conduct mentioned above are compliance violations and employees who learn of such activities can report them using the Ethics Hotline.
 In the event such activities occur, an investigation will be conducted under the supervision of the relevant vice president (or through the Ethics Hotline system if the incident is reported via the Ethics Hotline, which is independent of the executive function). If the suspicions are found to be factual, appropriate action will be taken, measures will be devised and implemented to prevent recurrence, and a report will be made to the Board of Directors. Employees found to have engaged in corruption will face disciplinary action in line with company regulations.