Compliance

Policy and Basic Approach

Along with sound, ethics-based business activities, the Metal One Group regards compliance with laws and regulations, internal rules and social norms as the key principle for fulfilling our corporate social responsibilities. Based on this principle, we adhere to fair, highly transparent business practices.

Under the Compliance Committee—chaired by our chief compliance officer—and based on the conduct standards and a code of conduct that executives and other employees are required to follow, we strive to ensure thorough compliance at Metal One and across the entire Group.

In addition, we place importance on identifying risks early, preventing problems before they arise, and preventing recurrences. This strengthens preventive initiatives throughout the Group. Based on the belief that compliance is crucial to protecting the company as well as every employee, we are using ongoing education and awareness-raising activities to raise awareness throughout the Group.

We have a system requiring employees and Group companies to promptly report compliance matters in the unlikely event that one does arise, so we can respond quickly and appropriately. Besides our internal consultation and reporting channels, we have a third-party reporting system with outside counsel serving as the point of contact, creating an environment in which people can seek advice with confidence.

Metal One Employee Code of Conduct

Basic Policy

Based on our corporate philosophies and code of conduct, all officers and employees of Metal One Corporation (the “Company”) must comply with all applicable laws, rules and regulations where they operate, international standards and rules, and all internal corporate rules. In addition, all officers and employees of the Company must act in a socially responsible manner by complying with generally accepted standards in the conduct of their business.

Basic Principles

To respect human rights, and refrain from discriminating on any basis, and engaging in any form of harassment.
To maintain a high regard for environmental considerations in conducting our business operations, and ensure that our business is conducted in an environmentally sustainable manner, and comply with treaties, laws and regulations concerning the environment.
To promote fair business practices and comply with trade laws and regulations.
To comply with the rules and regulations of international trade.
To protect and properly use confidential and proprietary information, protect the rights of the Company and respect the rights of others.
To refrain from engaging in insider trading.
To avoid conflicts of interest with the Company; maintain a distinction between corporate and private business.
To provide financial and accounting records and reports in a timely and accurate manner.
To maintain proper legal and ethical standards with respect to gifts and entertainment.
To resolutely oppose any organization, group or individual engaged in unlawful activities and do not provide money or other types of economic benefits to them.
To promptly report to or consult the superiors, the heads of organizational units, the personnel in charge of promoting compliance activities in each department, the relevant departments, compliance officers, the Secretariat for the Compliance Committee, or the outside counsel in charge of compliance, upon discovering or committing any violations of this Code of Conduct.

Metal One’s Compliance Structure

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Initiatives

Implementation of Compliance Education Activities

The Metal One Group conducts various compliance education and training programs to promote employee compliance awareness and ensure that executives and other employees possess the knowledge and information necessary for their work. This includes year-round e-learning, seminars and other programs. For example, we provide training on the laws, regulations, internal systems and company rules relevant to business operations. We also promote thorough compliance awareness from a variety of perspectives, ranging from the prevention of corporate corruption and bribery—including the Antimonopoly Act, the Subcontract Act and anti-bribery regulations—to human rights-related issues such as harassment prevention.

Initiatives That Raise Employee Compliance Awareness

We regularly issue compliance messages from the chief compliance officer and hold compliance discussions in each workplace to strengthen employee compliance awareness.

These compliance discussions cover topics such as issues that could arise in day-to-day work, and are conducted casually in small groups without regard to differences in seniority or job level. Our aim is to create an open workplace environment and reinforce each employee’s awareness of compliance. We hold compliance discussions at least once a year at Metal One and throughout the Group, including domestic and overseas offices and subsidiaries.

Compliance Monitoring Survey

In addition to compliance awareness initiatives, the Metal One Group regularly conducts compliance monitoring surveys involving Group executives and employees. These surveys use anonymous questionnaires to gather responses on the status of compliance observance within the Group, organizational culture, measures and systems—including mechanisms such as the internal reporting system—and to obtain candid evaluations and opinions from both executives and other employees. The results of these surveys are fed back to each organization and used to improve organizational culture and refine and formulate compliance measures.

Internal Reporting System

Metal One’s internal reporting system is designed to prevent compliance violations before they occur, ensure their early detection, and enable corrective action. By providing an environment in which employees and other relevant parties can confidently report violations of laws and regulations or conduct that breaches corporate ethics, we enhance organizational soundness and strengthen social trust.

The reporting channels are: (1) an outside counsel, (2) a corporate auditor hotline, (3) our LUKS internal reporting system for violations of antitrust and anti-bribery regulations, and (4) a business partner reporting channel. Metal One also has internal rules prohibiting the disadvantageous treatment of whistleblowers and ensures that they are thoroughly protected. Anonymous reports are also accepted. Unless there is a justifiable reason not to do so, we conduct the necessary fact-finding and investigations on all reported matters. If a violation is confirmed, we take appropriate corrective measures in coordination with the relevant departments.

Sustainability