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compliance

Compliance system and operational status

Group-wide compliance and risk management system

At our company, we have established a "Compliance and Risk Management Committee" as the main department responsible for cross-group risk management, and "Local Committees" under its umbrella at each business site, including subsidiaries, to establish a risk management system based on "Risk Management Regulations." In addition, we are working to further enhance corporate value by ensuring the effectiveness of our risk management system through the PDCA cycle for risks faced by each department and by conducting regular monitoring by the Internal Audit Department.

Compliance System

Diagram illustrating the compliance system.

Promoting compliance and risk management activities

Systems and transparency that are ingrained in daily operations

To ensure that compliance awareness is ingrained in every employee, we continue to conduct self-assessments and provide education using the "Risk Management Periodic Inspection Record Book" and "Compliance Text," and we also publish an internal newsletter called "RM Newsletter."

Furthermore, we are promoting the use of our compliance promotion portal site (internal portal) and aiming to further strengthen our governance system by improving employees' compliance awareness.

Policies and initiatives regarding spoilage prevention

Our group prohibits corrupt practices, including bribery, embezzlement, and collusion. Our Corporate Code of Conduct upholds "fair and transparent business activities," and explicitly states that we "will not engage in collusion in bidding" and "will conduct business with our business partners in an equal relationship based on contracts." Based on this principle, we have formulated an "anti-corruption policy" which is applied to all officers and employees of our group.

Furthermore, based on our compliance system, executives and employees are required to identify risks related to corruption and bribery. We have also created an ABC guidebook for corruption prevention for employees, which is disseminated and promoted through the company's internal portal site.

Furthermore, in fiscal year 2024, there were zero cases of disciplinary action or dismissal of executives or employees due to violations of the anti-corruption policy.

Please see the full text of the "Anti-Corruption Policy" here.

Import/export cargo management

To contribute to ensuring safety in international logistics and facilitating trade, our company is strengthening its compliance system. As part of this effort, we have developed programs for compliance with relevant laws and regulations, ensuring the security of international cargo, and proper import and export customs clearance, and we have established a management system based on these programs.

Furthermore, as an Authorized Economic Operator (AEO) with excellent compliance systems and security management, our company was approved as a designated bonded warehouse operator in June 2011 and as an authorized customs broker in January 2014.

Designated bonded warehouse operators: 54 registered bonded warehouses nationwide.

Certified customs brokers: 35 locations nationwide

(As of the end of March 2025)

Logo of an Authorized Economic Operator (AEO)

Thorough implementation and dissemination of information about the internal whistleblowing system

Our company has established an internal whistleblowing system, the "Corporate Ethics Helpline," with the aim of early detection and prevention of legal violations and misconduct, as well as improving internal self-correction. The Compliance and Risk Management Committee and the Board of Corporate Auditors serve as the reporting channels for matters that violate our Articles of Incorporation and Compliance Regulations, including compliance violations, harassment cases, and corruption including bribery. They handle reported cases while ensuring the anonymity of whistleblowers and those cooperating in investigations. As of the end of March 2025, 24 cases had been received.

"Kamigumi Corporate Ethics Helpline" Poster

"Kamigumi Corporate Ethics Helpline" Poster

Furthermore, we are making every effort to ensure the proper operation of the internal whistleblowing system by conducting employee training on the system, posting posters within our offices, and creating and distributing a guidebook, "The ABCs of the Kamigumi Group Corporate Ethics Helpline," so that all officers and employees can use the system with greater confidence.

Excerpt from "The ABCs of the Kamigumi Group's Corporate Ethics Helpline"

Excerpt from "The ABCs of the Kamigumi Group's Corporate Ethics Helpline"

Basic principles for eliminating anti-social forces

Our company has codified in our Corporate Code of Conduct that we will take a firm stance against anti-social forces. To achieve this, we have established internal systems such as including anti-gang clauses in various contracts and auditing the contents of those contracts. We also uphold the "Three No Principles (Don't be afraid, don't give them money, don't use them)" and strive to thoroughly instill and instill these principles throughout the entire group to ensure order and safety in civil society.

Responsible tax payment

Our company does not have its headquarters or any subsidiaries located in tax havens.