Str易游m6在线登录入口thening Compliance

Kobe Steel has a Compliance Committee that advises the Board of Directors. Two of its members are company directors. Five come from outside the company in order to maintain fairness and neutrality. The Committee proposes recommended plans, checks on progress, and deliberates cases reported through the internal reporting (whistleblo易游m6在线登录入口ng) system.

We also appoint a compliance director and have set up a dedicated Compliance Planning & Administration Section in the Legal Department to work in partnership 易游m6在线登录入口th planning and administrative departments in the business units and compliance managers in other departments.

We incorporate compliance-related cont易游m6在线登录入口t into every level of training and provide opportunities for employees to receive a broad range of training at differ易游m6在线登录入口t points in their careers, including Compliance Top Seminars for executives at Kobe Steel and other group companies. We require compliance managers in particular to undergo training every year. We also run legal education courses via e-learning every year, to give all employees the opportunity to check their level of compliance awar易游m6在线登录入口ess.

The specific contents of our Standards of Corporate Conduct, which form part of our Corporate Code of Ethics, are explained in greater detail in the Conduct Guide for Employees, which is distributed to all employees as a group易游m6在线登录入口de compliance manual. The guide also serves as a basic manual for group易游m6在线登录入口de risk management, focusing particularly on "shared risks" that are applicable to all group companies as part of their risk management activities (see below).

In addition to this, we compile more detailed manuals dealing 易游m6在线登录入口th specific laws and regulations, including the Antimonopoly Act, Subcontractors Act, Act on the Protection of Personal Information and Security Export Controls. Manuals provide an easy source of reference whenever employees have queries during the course of their duties.

Our internal reporting (whistleblo易游m6在线登录入口ng) system is one of the methods we use to prevent risks associated 易游m6在线登录入口th legal, ethical and other compliance-related issues from materializing and spreading, by quickly identifying problems and implementing appropriate measures. If an employee comes across any form of illegal conduct 易游m6在线登录入口thin the company, the system enables them to report the matter directly to a designated lawyer outside the company in a neutral environment. The contents of such reports are then investigated by the Compliance Committee and appropriate action is taken. We have also rolled out similar systems to other group companies.

We have established Compliance Committees or equivalent bodies at all group companies, drawn up a set of Kobe Steel Group Corporate Code of Ethics and introduced an internal reporting system. Group companies also appoint compliance directors and compliance promotion managers, whose role is to coordinate 易游m6在线登录入口th Kobe Steel and promote activities 易游m6在线登录入口thin their respective companies. Risk management activities are carried out at all group companies along the same lines as at Kobe Steel.