Regulations for Preventing Damage by Anti-Social Forces
Eliminating anti-social forces from society is a critical issue for maintaining social order and safety. To protect not only the Company and its officers and employees but also users and other stakeholders from harm, these Regulations set out the matters necessary to exclude anti-social forces from financial transactions.
Article 1Purpose
Recognizing that eliminating anti-social forces from society is an extremely important issue in ensuring social order and safety, and that promoting efforts to sever relationships with anti-social forces is necessary and important for a company to fulfil its social responsibility, the purpose of these Regulations is to set out the matters necessary to exclude anti-social forces from financial transactions, in order to prevent harm not only to the Company and its officers and employees but also to users and other stakeholders.
Article 2Definitions
“Anti-social forces” means organized crime groups, members of organized crime groups, persons who ceased to be members less than five years ago, associate members, companies affiliated with organized crime groups, corporate racketeers, persons engaging in criminal activities under the guise of social or political movements, special intelligence violent groups, and other equivalent persons (collectively, “Organized Crime Members, etc.”), or any person falling under any of the following:
Having a relationship in which Organized Crime Members, etc. are deemed to control its management.
Having a relationship in which Organized Crime Members, etc. are deemed to be substantially involved in its management.
Having a relationship in which it is deemed to make improper use of Organized Crime Members, etc., such as for the purpose of obtaining an unlawful benefit for itself, its company or a third party, or of causing damage to a third party.
Having a relationship in which it is deemed to be involved with Organized Crime Members, etc., such as by providing funds or other benefits to them.
Having a relationship in which an officer or a person substantially involved in its management has a socially reprehensible relationship with Organized Crime Members, etc.
Whether a person falls under “anti-social forces” shall be determined by focusing not only on the attributes listed in the preceding paragraph but also on the following conduct:
Violent demands
Unreasonable demands beyond legal responsibility
Threatening words or conduct, or use of violence, in connection with a transaction
Damaging the other party’s credibility or obstructing its business by spreading rumours, using fraudulent means or using force
Any other conduct equivalent to the foregoing
Article 3Establishment of Responsible Department
Management shall be appropriately involved in severing relationships with anti-social forces and shall respond as an organization.
The Compliance Department shall be the department responsible for overseeing the Company’s response to anti-social forces.
The Compliance Department shall separately establish a response manual to prevent damage by anti-social forces.
Article 4Development of Databases, etc.
To prevent damage by anti-social forces, the Compliance Department shall establish the following frameworks:
A database of information obtained regarding anti-social forces (including a framework for appropriately adding, deleting and changing information)
A framework for cooperation with the competent police, the Center for the Elimination of Boryokudan and legal advisers
A response manual
Article 5Exclusion Clauses and Verification of Shareholders
To prevent transactions with anti-social forces, the Company shall, to the extent possible, include anti-social forces exclusion clauses in its contracts and terms of business.
Once a year, the Company shall confirm whether any anti-social forces are among its shareholders.
Article 6Prior Screening
To prevent transactions with anti-social forces, the Company shall conduct prior screening of its transactions in accordance with its business characteristics, using the information managed in the database under Article 4.
Article 7Post-Transaction Verification
To thoroughly sever relationships with anti-social forces, the Company shall establish a framework for appropriately verifying existing contracts and shall conduct such verification in accordance with its business characteristics.
Article 8Response When a Transaction with Anti-Social Forces Is Identified
Any department that obtains information indicating a transaction with anti-social forces shall promptly report to and consult with the Compliance Department.
The Compliance Department shall promptly and appropriately report such information to management and, under management’s direction and involvement, work closely with the police, the Center for the Elimination of Boryokudan, lawyers and other external specialists as necessary to sever the relationship, taking care not to confer any benefit on anti-social forces.
Article 9Response to Unreasonable Demands
When an unreasonable demand by anti-social forces occurs, the following actions shall be taken to prevent damage:
The department where the demand occurred shall promptly report to and consult with the Compliance Department.
Where the Compliance Department deems it necessary, such as when the risk of threats or violence is high and the matter is urgent, it shall notify the police.
Giving top priority to the safety of the staff handling the matter, the Compliance Department shall instruct the department on appropriate action.
A report shall be made to management via the Compliance Department, seeking instructions as necessary.
The police, the Center for the Elimination of Boryokudan, lawyers and other external specialists shall be consulted.
In making such reports or consultations, all civil legal remedies shall be considered and, particularly where the risk of threats or violence is high and urgent, the Company shall not hesitate to pursue criminal proceedings, such as by immediately filing a damage report.
Article 10Investigation of Facts
Where an unreasonable demand by anti-social forces is based on misconduct in business activities or by an employee, the Compliance Department shall promptly investigate the facts.
Article 11Awareness and Training
The Compliance Department shall ensure that officers and employees are fully informed so that damage by anti-social forces is appropriately prevented.
The Compliance Department shall ensure that the relevant officers and employees accurately understand the following:
The overall policy for dealing with anti-social forces
The response when a transaction with anti-social forces is identified
The reporting system for unreasonable demands
The response framework for unreasonable demands
Any other matters necessary to prevent damage by anti-social forces
Officers and employees shall be informed by the following methods:
Internal training
Notification of internal rules by documents, email, etc.
Making internal rules available for viewing within the Company
Such awareness activities shall be conducted at least once a year.
Article 12Verification of Operations
The Compliance Department shall confirm the following with respect to operations under these Regulations:
Relationships with anti-social forces are appropriately severed.
Response measures for unreasonable demands are in place.
Reporting and consultation systems for unreasonable demands are in place.
The Compliance Department shall report the results of such confirmation to management once a year, except where a prompt report is required according to individual circumstances.
AnnexResponse Manual
1. Preventive measures
Creating an environment that prevents damage
Based on this manual, each office and counter shall be prepared at all times for unreasonable demands.
Each office and counter shall display the basic policy or anti-organized-crime posters to make the Company’s stance clear.
Reporting system (route: department concerned ⇔ Compliance Department ⇔ management; in an emergency, call the police on 110 / the competent police station)
The department concerned shall ensure staff safety, respond in line with “4. Response procedures” below, and promptly report to the Compliance Department.
The Compliance Department shall advise the department on response measures, including staff safety, report to management and, if urgent, notify the police.
Management shall consider the response based on the report and give instructions as necessary.
2. Examples of unreasonable demands
Demanding money in the name of donations or support payments
Demanding hush money in connection with misconduct, etc.
3. Basic attitude
Never accept unreasonable demands for any reason.
Know your own work well so you can respond with confidence.
Do not leave the person in charge alone; respond cooperatively within the department.
Clearly point out illegal acts (threats, refusal to leave, etc.) and report them to the police.
4. Response procedures
Confirm who the other party is (record their details for reporting).
Confirm the matter (have them state their specific demand).
Always respond at a location favourable to you (e.g. on company premises) and with more than one person (avoid meeting outside where possible).
Be careful with words and conduct (do not make impossible promises or careless remarks such as “we will consider it” that raise expectations).
Do not create unnecessary documents (do not agree to write memoranda or affix seals).
Take a firm stance (respond on the basis that no unreasonable demand will be accepted; if the other party is not satisfied after a full explanation, do not prolong the matter, request that they leave, and state that you will not hesitate to call the police).
5. Consultation
Where there is a case that may lead to an unreasonable demand, consult the relevant section of the prefectural police or the Center for the Elimination of Boryokudan.
Established: June 25, 2012 / Revised: April 6, 2021; June 30, 2022; April 1, 2023. This English version is a translation; in the event of any discrepancy, the Japanese version prevails.