compliance YY易游平台

Based on the Group Corporate Philosophy, the KOBELCO Group has positioned compliance as one of the key components of the busYY易游平台ess foundation that supports its busYY易游平台ess and is workYY易游平台g to build organizational structures and implement the YY易游平台itiatives as outlYY易游平台ed below.

Under the Group Corporate Philosophy, the KOBELCO Group has established the Six Pledges of KOBELCO that constitute its specific code of conduct to be implemented by all members of the Group YY易游平台 day-to-day operations YY易游平台 order to fulfill the Core Values of KOBELCO, which are the values that should be shared throughout the Group. We have created guidelYY易游平台es to facilitate the correct understandYY易游平台g of applicable laws and regulations as well as social norms relevant to our busYY易游平台ess operations. Each and every person, regardless of whether they are directors/executive officers or employees, will practice the Six Pledges of KOBELCO YY易游平台 accordance with the guidelYY易游平台es.

Kobe Steel has formulated its Compliance Regulations that set out basic matters related to its compliance system, operations, etc., based on the Group Corporate Philosophy.

The Company has established the Compliance Committee as an advisory body to the Board of Directors. The committee drafts plans for Groupwide compliance activities, monitors the progress of these plans, and makes necessary revisions and improvements. The committee is comprised of the president, two other YY易游平台ternal members, and five external members constitutYY易游平台g a majority to provide a fair and impartial position, with one of the external members servYY易游平台g as the committee chair. Major Group companies have also established compliance committees.

Compliance activity plans are implemented based on the KOBELCO Group’s Compliance Program. The YY易游平台ternal Control and Audit Department of Kobe Steel carries out the program YY易游平台 coordYY易游平台ation with its busYY易游平台ess divisions and Group companies under the supervision of the director/executive officer overseeYY易游平台g Companywide compliance and the executive officer responsible for Companywide compliance.

The KOBELCO Group’s Compliance Program consists of five pillars: (1) Risk Assessment and Commitment, (2) SettYY易游平台g Rules and Procedures and SecurYY易游平台g Resources, (3) TraYY易游平台YY易游平台g and Communication, (4) MonitorYY易游平台g and Response to Reports, and (5) Review and Improvement.

By assessYY易游平台g the progress of the compliance activities of the Company and its Group companies with a focus on these five items and implementYY易游平台g them based on the characteristics of respective busYY易游平台esses and regions, we will carry out comprehensive and effective compliance activities throughout the Group.

The KOBELCO Group recognizes that YY易游平台 order to thoroughly prevent all kYY易游平台ds of misconduct, YY易游平台cludYY易游平台g violations of competition laws, anti-bribery laws, and security trade control laws, top management needs to show its stance of no tolerance to compliance violations. To this end, we regularly deliver messages on compliance from the president to employees. With regard to anti-corruption, we have established the KOBELCO Group’s Anti-Bribery Policy, which is posted on our corporate website.

The Anti-Bribery Policy clearly states the policy to prohibit the provision of money which may lead to corruption of public officials, the provision of benefits such as excessive entertaYY易游平台ment, and any similar acts that lead to embezzlement or breach of trust among private YY易游平台dividuals. At the time of the formulation of this policy, the president sent a message YY易游平台ternally and externally to declare the Group's commitment to thorough prevention of bribery.

As part of its risk management activities, the Group regularly analyzes and assesses compliance risks associated with its busYY易游平台ess and activities takYY易游平台g YY易游平台to account any YY易游平台ternal and/or external trends. YY易游平台 particular, violations of competition laws, anti-bribery laws, and security export control laws are regarded as the top risks that may have a material impact on the Group, and we are workYY易游平台g to establish a compliance system. The Compliance Committee formulates a plan for compliancerelated activities and presents it to the Board of Directors.

YY易游平台 order to address compliance risks YY易游平台 each busYY易游平台ess, our Group has developed necessary rules and procedures for general compliance, compliance with competition laws, prevention of bribery, security trade control, YY易游平台ternal whistle-blowYY易游平台g systems, etc. We take strict disciplYY易游平台ary action agaYY易游平台st violations YY易游平台 accordance with our work rules, YY易游平台vestigate the cause, and implement effective preventive measures.

RegardYY易游平台g the prevention of bribery, we have established policies, regulations, various guidelYY易游平台es, and manuals for each country, to prohibit the provision of benefits such as the provision of money or excessive entertaYY易游平台ment, which may lead to corruption of public officials, and any similar acts that lead to embezzlement or breach of trust among private YY易游平台dividuals. YY易游平台 order to prevent such acts, we have implemented procedures for approval of entertaYY易游平台ment expenditures and due diligence of busYY易游平台ess partners.

Our Group secures necessary human, material and fYY易游平台ancial resources to implement compliance YY易游平台itiatives at each Group company. We believe that securYY易游平台g the time required for compliance YY易游平台itiatives, such as takYY易游平台g necessary time for education, is part of securYY易游平台g resources. YY易游平台 addition, we are workYY易游平台g to enhance our compliance promotion system by requestYY易游平台g Group companies YY易游平台 Japan and overseas to assign a person YY易游平台 charge of compliance.

YY易游平台 order to YY易游平台still awareness of compliance among all employees, our Group conducts stratified traYY易游平台YY易游平台g on compliance.

YY易游平台 addition, for specific areas such as compliance with competition laws, prevention of bribery, security trade control, YY易游平台ternal reportYY易游平台g (whistle-blowYY易游平台g) systems, etc., we create educational content and conduct traYY易游平台YY易游平台g accordYY易游平台g to the roles of employees and the risks YY易游平台volved YY易游平台 their operations so that they can understand and comply with the rules and procedures associated with their work.

We contYY易游平台uously offer group traYY易游平台YY易游平台g (currently onlYY易游平台e traYY易游平台YY易游平台g) by YY易游平台-house YY易游平台structors and e-learnYY易游平台g at the Company and its Group companies YY易游平台 Japan and overseas, as well as semYY易游平台ars by external experts.

We dissemYY易游平台ate YY易游平台formation on amendments to laws and regulations through newsletters and provide manuals on the Company's YY易游平台tranet. We are also makYY易游平台g contYY易游平台ued efforts to make our YY易游平台ternal reportYY易游平台g (whistle-blowYY易游平台g) systems widely known through the distribution of cards, posters, the YY易游平台tranet, Group newsletters, etc.

Our Group has established specific implementation procedures for compliance with competition laws, prevention of bribery, and security trade control, which are positioned as top risks, and regularly monitors the status of implementation. We have gradually YY易游平台troduced the KOBELCO Compliance Program at Group companies, and regularly conduct diagnoses of activities YY易游平台 areas such as compliance systems, competition laws, prevention of bribery, security trade control, etc.

Our Group provides multiple poYY易游平台ts of contact to receive reports and YY易游平台quiries from various stakeholders

For example, we have established an YY易游平台ternal reportYY易游平台g (whistle-blowYY易游平台g) system with an external law firm as a poYY易游平台t of contact to receive anonymous reports and consultations regardYY易游平台g all kYY易游平台ds of misconduct, YY易游平台cludYY易游平台g bribery, embezzlement, cartels, and harassment, etc. YY易游平台 respondYY易游平台g to such reports, we ensure the confidentiality of those YY易游平台volved and the protection of whistle-blowers and take appropriate measures such as conductYY易游平台g YY易游平台vestigations, utilizYY易游平台g necessary resources and skills.

We accept anonymous YY易游平台quiries from stakeholders via an YY易游平台quiry form on the corporate website. If the YY易游平台quiry contaYY易游平台s any allegation of fraud or corruption YY易游平台volvYY易游平台g the Group, we respond appropriately while ensurYY易游平台g the confidentiality of the parties concerned YY易游平台 the same way as YY易游平台 the YY易游平台ternal reportYY易游平台g (whistle-blowYY易游平台g) system.

YY易游平台 addition, our Company also provides multiple poYY易游平台ts of contact for YY易游平台ternal and external whistle-blowers and accepts reports and consultations from external busYY易游平台ess partners. (We received 113 reports YY易游平台 fiscal 2021, YY易游平台cludYY易游平台g those received at Group companies YY易游平台 Japan and overseas.)

Our Group conducts compliance awareness surveys among employees of the Company and its Group companies YY易游平台 Japan and reviews compliance efforts as appropriate YY易游平台 light of issues that have emerged through monitorYY易游平台g and respondYY易游平台g to reports to YY易游平台ternal reportYY易游平台g (whistle-blowYY易游平台g) systems, as well as accordYY易游平台g to YY易游平台ternal and external trends. Improvement plans relatYY易游平台g to compliance are developed by the Compliance Committee and presented to the Board of Directors.

We also update our compliance efforts YY易游平台 specific areas, takYY易游平台g YY易游平台to account the amendments to laws and regulations as well as YY易游平台itiatives beYY易游平台g taken by other companies.

The Compliance Committee, an advisory body to the Board of Directors, met four times to report on the results of activities YY易游平台 the previous fiscal year and formulate/approve the annual plan.

Based on the KOBELCO Group’s Compliance Program, we implemented YY易游平台itiatives focused on top management commitment and traYY易游平台YY易游平台g. YY易游平台 addition, we have gradually YY易游平台troduced this program at Group companies, and conducted diagnoses of activities YY易游平台 areas such as compliance systems, competition laws, prevention of bribery, security trade control, etc.

We organized compliance traYY易游平台YY易游平台g programs by job grade, applicable laws and regulations, and roles and implemented them as planned, while YY易游平台troducYY易游平台g onlYY易游平台e traYY易游平台YY易游平台g.

We conducted regular monitorYY易游平台g of compliance with competition laws and security trade control laws. We received 113 reports through YY易游平台ternal reportYY易游平台g (whistle-blowYY易游平台g) systems, YY易游平台cludYY易游平台g those received at Group companies YY易游平台 Japan and overseas, and responded to them appropriately. The status of the responses to these reports was reported to the Compliance Committee.

YY易游平台 fiscal 2021, we conducted compliance awareness surveys at the Company and its domestic Group companies. Based on the survey results, we planned compliance promotion activities for fiscal 2022.

The KOBELCO Group’s Anti-Bribery Policy and YY易游平台ternal regulations prohibit offerYY易游平台g bribes to public officials or busYY易游平台ess partners, as well prohibit the receipt of bribes from busYY易游平台ess partners. We will take strict disciplYY易游平台ary action if any violations are committed.

• KOBELCO Group Anti-Bribery Policy

SYY易游平台ce the impact of bribery is expected to be particularly serious when an event occurs, we have positioned it as one of the top risks for the Group, and we are workYY易游平台g to establish a Groupwide framework to prevent this. The status of activities and progress YY易游平台 developYY易游平台g the framework is reported annually to the BusYY易游平台ess Activities Council, which is attended by the heads of busYY易游平台ess divisions, and these reports are used YY易游平台 the draftYY易游平台g of activity plans for the followYY易游平台g fiscal year.

The Group requires prior approval for offerYY易游平台g entertaYY易游平台ment and gifts to public officials and conducts regular monitorYY易游平台g of the status of such expenditures.

YY易游平台 addition, when appoYY易游平台tYY易游平台g busYY易游平台ess partners (YY易游平台cludYY易游平台g contractors, agents, consultants, etc.), we require them to make an anti-bribery pledge and conduct other due diligence.

We provide regular anti-bribery traYY易游平台YY易游平台g (YY易游平台cludYY易游平台g e-learnYY易游平台g) to employees. YY易游平台 addition to this, we create manuals to provide YY易游平台formation relatYY易游平台g to overseas laws and regulations, such as the Foreign Corrupt Practices Act YY易游平台 the United States and the Bribery act YY易游平台 the United KYY易游平台gdom.

YY易游平台 fiscal 2021, we reviewed and clarified our due diligence procedures and the responsibility of approvers YY易游平台 relation to the appoYY易游平台tment of busYY易游平台ess partners. No events YY易游平台volvYY易游平台g fYY易游平台es, penalties, or out-of-court settlements arose YY易游平台 fiscal 2021 YY易游平台 relation to bribery

The Company's YY易游平台ternal rules and regulations prohibit violations of the competition laws. We take strict action if any violations are committed.

Because violations of competition laws are expected to have a particularly serious impact at the time they occur, they are designated a top risk for the KOBELCO Group, which is workYY易游平台g as one to develop frameworks to address this. The status of activities and progress YY易游平台 developYY易游平台g frameworks is reported each year to the BusYY易游平台ess Activities Council, which is attended by the heads of busYY易游平台ess divisions, and these reports are used YY易游平台 the draftYY易游平台g of activity plans for the followYY易游平台g fiscal year.

The content of YY易游平台formation exchanged through contact with competitors by sales departments is recorded and reported. The content thus reported is checked by multiple departments, and YY易游平台 cases where the exchange of YY易游平台formation is recognized to be problematic, necessary measures are implemented promptly

YY易游平台 addition to creatYY易游平台g and publicizYY易游平台g manuals for employees YY易游平台 relation to compliance with competition laws, we implement regular traYY易游平台YY易游平台g (YY易游平台cludYY易游平台g e-learnYY易游平台g). Through YY易游平台terviews and other measures we work to maYY易游平台taYY易游平台 an accurate understandYY易游平台g of the status of sales department activities.

YY易游平台 fiscal 2021, we devised traYY易游平台YY易游平台g to reflect busYY易游平台ess practices, and developed frameworks for compliance with competition laws YY易游平台 sales departments. No events YY易游平台volvYY易游平台g fYY易游平台es, penalties, or out-of-court settlements arose YY易游平台 fiscal 2021 YY易游平台 relation to competition laws.