Compliance

• Basic concept
• H-one Group Code of Conduct
• Promotion system
• Governance Committee’s activities
• CSR initiatives in the supply chain
• Initiatives toward eradicating the use of conflict minerals

Basic concept

We consider that protecting sound business activities is a foundation indispensable for our Group to build and maintain trust of our customers, business partners, and society and to continue to grow into the future.
Based on this awareness, we promote compliance activities based on the policies set forth in the “H-one Group Code of Conduct.”

H-one Group Code of Conduct

Compliance

H-one group policy

H-one group continuously carries out initiatives to strengthen compliance in order to reinforce the trust established with society. Persons who work at H-one group are also required to comply with relevant laws, regulations, and policies while acting ethically.

Required conduct

I will comply with laws, regulations and company policies.
I will act ethically in accordance with social norms and common sense.

Reporting Non-compliance Incidents

If I become aware of any violation or possible violation of laws, regulations or company policies, I will report the matter to the company through my manager, the compliance & ethics contact line, or other corporate communication methods.

Promotion system

In our company, the Governance Committee chaired by the Compliance Officer continuously implements various activities related to compliance. The members of the Committee are elected from each business site. The Committee plans and promotes the activities and also promptly responds to whistle-blower cases.

Governance Committee’s activities

Enlightenment and education activities for employees

• Handbooks are distributed for dissemination regarding the “H-one Group Code of Conduct” and “Divisional Code of Conduct” in keeping with the actual conditions of operations of the production, development, and head office divisions as well as important laws and regulations.
• By holding regular study sessions targeting all employees, we are all enlightened about compliance violation cases, harassment cases, the whistle-blower system, and actions to be taken based on the Code of Conduct.
• Similar enlightenment is carried out in hierarchical training (of new employees, newly appointed managers, etc.).

“H-one CG self-assessment”

“H-one CG self-assessment” activities are conducted every year to check the implementation status of legal compliance initiatives relating to operations. In the activities, all departments perform a self-assessment based on a check sheet that contains a wide range of compliance items related to laws and regulations as well as company regulations from two perspectives: systems to observe rules, and the effectiveness of system functions.
The results of the assessment is not only connected to the improvement of issues and events but also reported at the Board of Directors and the Management Committee and utilized for internal and external audits.

Whistle-blower system

We have established and maintain and operate a whistle-blower system for the purpose of early discovery and correction of business ethics violations, such as business laws and regulations violations and workplace harassment.
All employees including contract employees and dispatched employees as well as business partners may blow a whistle. We have set up not only an in-house window, but also an outside window at an outside law firm, and a global window to accept whistle-blowing from overseas associates.
In the operation of these windows, confidentiality of persons in charge and protection of whistle-blowers are defined by company regulations, and we conduct careful investigations so as not to disadvantage whistle-blowers from the viewpoint of whistle-blower protection, and make efforts to prevent recurrence after confirmation of facts.
If a whistle is blown, the Governance Committee plays a central role in confirming the facts and taking measures as mentioned above, and reports the results at the Board of Directors and the Management Committee.

CSR initiatives in the supply chain

We issued “Supplier CSR Guidelines” in FY2016, and we are jointly tackling CSR activities including compliance with our business partners. In addition to holding regular briefings to raise awareness and understanding of CSR activities, we request regular self-evaluations to check the status of company-by-company initiatives and problems.
We will continue to build a constructive relationship with our business partners, while gaining awareness and understanding of CSR activities and cooperation from them as a matter of policy.

Initiatives toward eradicating the use of conflict minerals

Some of 3TGs (tin, tantalum, tungsten, and gold: hereinafter referred to as “conflict minerals”) produced in conflict-affected regions are sources of funding for inhumane acts conducted by armed insurgents, and there is concern about the potential for human rights violations, environmental destruction, etc.
Initiatives toward eradicating the use of conflict minerals are progressing globally as “the Dodd–Frank Wall Street Reform and Consumer Protection Act” that was enacted in July 2010, which requires U.S.-listed companies to concretely understand whether conflict minerals are used in their own products.
Although we are under no obligation to report based on the Act, we promote initiatives toward eradicating the use of conflict minerals throughout each supply chain in light of the fact that our customer car manufacturers are listed on U.S. stock exchanges.
Specifically, we not only conduct surveys regarding the inclusion of conflict minerals with cooperation from our business partners on a yearly basis, but also clearly stipulate the prohibition of the use of conflict minerals in the “Supplier CSR Guidelines.”
We will continue to work to eradicate the use of conflict minerals.