Sophia School Corporation Whistleblowing Regulations
EnactedAmendedApril 1, 2009
April 1, 2011
October 1, 2022

April 1, 2012
November 9, 2022

April 1, 2014
April 14, 2023

April 1, 2016

Chapter 1. General Provisions(Purpose)
Article 1.
The purpose of these regulations is to contribute to the maintenance of public trust in the Sophia
School Corporation (hereinafter referred to as the "Corporation") and the assurance offairness/impartiality in the conduct of its affairs by stipulating necessary matters in relation to its
whistleblowing system so that illegal conduct in the affairs of the Corporation or
improper/inappropriate conduct contrary to the Corporation's regulations (hereinafter referred to as"Wrongful Conduct") is early detected and rectified and whistleblowers are protected in the
Corporation and schools established by the Corporation in accordance with the Whistleblower
Protection Act (Act No. 122 of 2004; hereinafter referred to as the "Act").
(Definition)
Article 2.
Terms used in these regulations shall be construed in accordance with the following definitions.
(1) Whistleblowing Disclosure: A report on the occurrence or potential occurrence of Wrongful
Conduct to the whistleblowing desk set forth in Article 8 from one or more executives, faculty
and staff members (including dispatched workers, employees engaged in certain work at the
Corporation under a service or other contract with the Corporation, employees of each contractor
under a contract with the Corporation, and persons who retired within one year retroactively
from the date of whistleblowing; the same applies throughout these regulations), and students
enrolled in Sophia University, the Graduate Programs of Sophia University, or Sophia University
Junior College Division (hereinafter referred to as "Faculty, Staff, and Other Members") withouta wrongful purpose such as a purpose of acquiring a wrongful gain or causing damage to others.
(2) Whistleblower: A person who makes a Whistleblowing Disclosure.
(3) Beyond-Minimum Sharing: Sharing beyond the requisite minimum of information from which
one or more Whistleblowers can be identified.
(Responsibilities of Chancellor, Trustees, and Heads of Schools Established by the Corporation)
Article 3.
The Chancellor, Trustees, and heads of schools established by the Corporation must endeavor toprevent and eliminate Wrongful Conduct that may impede the maintenance of public trust in the
Corporation and fairness/impartiality in the conduct of its affairs, and in the event of Wrongful
Conduct occurring, they must promptly and appropriately institute measures in accordance with these1regulations and associated Corporation's regulations.
(Responsibilities of Managers, Supervisors, Directors)
Article 4.
Those in positions involving management, supervision, or direction of affairs of the Corporation andschools established by the Corporation must endeavor to promote compliance with laws andregulations and the Corporation's regulations in the organs they manage, supervise, or direct.
(Responsibilities of Faculty and Staff Members)
Article 5.
The faculty and staff members must have a profound awareness of the importance of complying withlaws and regulations and the Corporation's regulations, and must at all times endeavor to performtheir work duties fairly and impartially in order to contribute to the advancement of education andresearch.
(Responsibilities of Whistleblowers)
Article 6.
Whistleblowers shall make Whistleblowing Disclosures based on objective and reasonable grounds
and may not make it for dissatisfaction with personnel treatment, for discrediting others, or for any
other wrongful purpose.
(Thorough Confidentiality and Protection of Personal Information)
Article 7.
1. None of the persons who are involved in the responses to one or more Whistleblowing Disclosuresor consultations stipulated in Paragraph 2 of Article 8 (including the persons who obtainconfidential information on the Whistleblowing Disclosures through ancillary work; hereinafterreferred to as the "Involved Persons") may not divulge the confidential information on the
Whistleblowing Disclosures.
2. None of the Involved Persons may, without due cause, disclose/divulge the personal informationthat he or she obtained (the personal information of one or more Whistleblowers and all otherpersons related to the content of the relevant disclosure) to any third party or use the personal
information for a purpose other than the prescribed purpose.
3. Each Involved Person shall continue to have the obligations in this article even after he or she
retires.
Chapter 2.

Whistleblowing Disclosure Response Systems(Whistleblowing Desk)
Article 8.
1. The Corporation shall have a whistleblowing desk that responds to Whistleblowing Disclosures inorder to promote compliance with laws and regulations and the Corporation's regulations.
22. The whistleblowing desk shall respond to ex-ante or ex-post consultations on Whistleblowing
Disclosures.
3. The whistleblowing desk shall be located in the Audit Office (with certain persons in charge ofWhistleblowing Disclosures).
4. A whistleblowing contact person shall be assigned in order to respond to Whistleblowing
Disclosures appropriately and the Deputy Director of the Audit Office shall act as thewhistleblowing contact person.
5. Notwithstanding the preceding two paragraphs, cases in which a whistle (including ex-ante or expost consultations) is blown on any of the Deputy Director and staff members of the Audit Officeshall be reported to the Office of General Affairs. The whistleblowing contact person in those cases
shall be the Director of the Bureau of General Affairs.
(Whistleblowing Committee)
Article 9.
1. The Corporation shall have the Whistleblowing Committee in order to establish a whistleblowing
disclosure response system and to ensure the fair/impartial performance of duties.
2. The Whistleblowing Committee shall engage in the following work.
(1) Investigation of facts and other necessary matters in relation to Whistleblowing Disclosures(2) Investigation of facts and other necessary matters in relation to disadvantageous treatment ofWhistleblowers, Beyond-Minimum Sharing, and search for Whistleblowers(3) Implementation of other important matters in relation to Whistleblowing Disclosures.
(Composition of Whistleblowing Committee)
Article 10.
1. The Whistleblowing Committee shall be composed of the following members.
(1) Trustee for General Affairs(2) Director of the Bureau of General Affairs(3) Deputy Director of the Audit Office
2. Notwithstanding the preceding paragraph, when the Whistleblowing Committee investigates into
the details of or otherwise responds to a Whistleblowing Disclosure, the chair may appoint on atemporary member from persons other than the members stipulated in the preceding paragraph.
3. Any members who are involved in a reportable case shall be excluded from the members
constituting the Whistleblowing Committee. In such case, if the number of members becomes lessthan three, the chair shall appoint the required number of members.
4. If necessary, the Whistleblowing Committee may have one or more faculty and staff members who
are not its members or outside attorneys and other professionals serve in the committee and hear
their opinions.
5. The Trustee for General Affairs shall be the chair, and shall convene the committee and chair its
meetings.
6. If the chair is incapacitated or excluded from the members constituting the Whistleblowing

3Committee as stipulated in Paragraph 3, a member nominated by the chair in advance or a member
elected by the committee from among its members shall perform the chair's duties.
7. The term of members shall be as follows.
(1) The members in Paragraph 1 shall serve for the term of office of their present workplace
appointment.
(2) The members appointed by the chair as stipulated in Paragraph 2 or the second sentence ofParagraph 3 shall serve until the end of processing of the relevant Whistleblowing Disclosure.
8. Matters necessary for the operation of the Whistleblowing Committee other than those stipulated
in Paragraph 1 through the preceding paragraph shall be as stipulated by the Whistleblowing
Committee.
(Designation of Engaged Persons)
Article10-2.
1. The Corporation shall designate the Chancellor, the persons in charge of the whistleblowing desk,
the whistleblowing contact person, the members of the Whistleblowing Committee, and themembers of the investigation team stipulated in Article 13 as the engaged persons provided for in
Article 11, paragraph (1) of the Act (hereinafter referred to as the "Engaged Persons").
2. Persons who are not the persons stipulated in the preceding paragraph but are engaged in the
responses to one or more Whistleblowing Disclosures and receive information from which therelevant Whistleblowers can be identified shall be designated as the Engaged Persons by the Trustee
for General Affairs in writing or by other means that makes it clear to the persons that they become
Engaged Persons.
Chapter 3.

Whistleblowing Procedures(Whistleblowing Disclosures)
Article 11.
When a Faculty, Staff, or Other Member becomes aware that another Faculty, Staff, or Other Member
is engaging in certain Wrongful Conduct that falls under any of the following items or considers that
there is a possibility of that Wrongful Conduct, he or she may report the details thereof to thewhistleblowing desk in his or her name or on an anonymous basis.
(1) Conduct that breaches or potentially breaches any of the relevant laws and regulations, theCorporation's regulations, and other relevant rules(2) Conduct that is not the conduct in the preceding item and that damages or potentially damages
the public trust in the Corporation or the fairness/impartiality in the conduct of its affairs(3) Other improper or inappropriate conduct(Acceptance of Whistleblowing Disclosures)
Article 12.
1. When the whistleblowing contact person receives a Whistleblowing Disclosure at the4whistleblowing desk, he or she shall promptly report thereof to the chair.
2. The whistleblowing contact person shall minimize the number of persons who may browse/share
the records/materials of the received Whistleblowing Disclosure and shall record theirbrowsing/sharing history.
3. In order to prevent Beyond-Minimum Sharing in reporting to the chair, the whistleblowing contact
person shall not convey information from which the relevant Whistleblower(s) can be identified
unless it is unavoidably required to make the investigations under the following article.
4. The chair shall submit the reported Whistleblowing Disclosure to the Whistleblowing Committee
and the committee shall determine whether or not to accept it. In such case, the Whistleblowing
Committee shall accept the Whistleblowing Disclosure unless there is a just cause.
(Investigation)
Article 13.
1. If the Whistleblowing Committee accepts a Whistleblowing Disclosure in accordance with thepreceding article, it shall promptly investigate the truth, falsity, etc. of the content of the
Whistleblowing Disclosure.
2. In making investigations under the preceding paragraph, the Whistleblowing Committee shallestablish an investigation team composed of one or more committee members designated by thecommittee and outside legal and other professionals.
3. In making investigations under Paragraph 1, the investigation team may require related parties tosubmit necessary materials or hear their explanations or opinions.
4. The investigation team must report to the Whistleblowing Committee in writing on the findings ofthe investigations and relevant materials that clarify the existence or non-existence of Wrongful
Conduct, the reason thereof, and other necessary matters.
5. The investigation team may provide the Whistleblowing Committee with an opinion about themeasures necessary to cease, rectify, and prevent the recurrence of the Wrongful Conduct based on
the findings of the investigations.
6. The Chancellor, Trustees, heads of schools established by the Corporation, and faculty and staff
members must cooperate with such investigations unless there is a just cause.
(Handling of Minor Disclosures)
Article 13-2.
1. Notwithstanding the preceding article, the investigations under the preceding article may besubstituted by the findings of hearings of facts, etc. from related parties, collection of materials, orother necessary fact-check investigations by the whistleblowing contact person as instructed by thechair if the chair considers that the content of a disclosure is minor or that it is necessary in termsof keeping the content of a disclosure confidential. One or more members of the Whistleblowing
Committee may attend the hearings in such case.
2. If hearings are done in accordance with the preceding paragraph, the whistleblowing contact person
shall report to the Whistleblowing Committee on the findings of the hearings.

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(Reporting to the Chancellor)
Article 14.
1. The Whistleblowing Committee shall report to the Chancellor on the findings of the investigations
under Article 13 or the preceding article.
2. When making a report under the preceding paragraph, the Whistleblowing Committee may provide
an opinion about the measures to be taken by the Chancellor under Paragraph 1 of the following
article. However, the Chancellor shall not be bound by this opinion.
(Rectification Measures and Recurrence Prevention Measures upon Whistleblowing Disclosures)
Article 15.
Upon receiving a report under the preceding article from the Whistleblowing Committee, theChancellor must, in light of the truth, falsity, and seriousness of the content of the reported
Whistleblowing Disclosure, institute measures necessary to cease the Wrongful Conduct in the factsof the Whistleblowing Disclosure or to restore it to a state complying with legal requirements andinstitute measures necessary to prevent its recurrence.
(Protection of Whistleblowers)
Article 16.
1. The Corporation shall, in compliance with the Whistleblower Protection Act and other relevantlaws, regulations, and rules, refrain from any disadvantageous treatment (including moral
harassment; the same applies hereinafter) in appointment, salary, or any other aspect of employment
and workplace conditions on the grounds of making a Whistleblowing Disclosure.
2. If a Whistleblower is a dispatched worker under a worker dispatch contract, an employee engaged
in certain work at the Corporation under a service or other contract with the Corporation, or an
employee of a contractor under a contract with the Corporation, the Corporation shall not cancel
the worker dispatch contract or the service or other contract, replace the dispatched worker withanother worker, or otherwise treat him or her in a disadvantageous manner on the grounds that heor she made a Whistleblowing Disclosure.
3. If a Whistleblower is a student enrolled in one of the schools established by the Corporation, theCorporation shall not subject the student to a reprimand, suspension, or expulsion from school orotherwise treat the student's education and research activities in a disadvantageous manner on the
grounds that the student made a Whistleblowing Disclosure.
(Rectification of Disadvantageous Treatment)
Article 17.
1. Each Whistleblower may lodge a complaint to the Whistleblowing Committee via thewhistleblowing desk if he or she has suffered disadvantageous treatment that seems to be on the
grounds that he or she made a Whistleblowing Disclosure.
2. If a complaint is lodged in accordance with the preceding paragraph, the Whistleblowing

6Committee shall promptly investigate the truth, falsity, etc. of the details thereof. However, suchinvestigations may be substituted by the findings of hearings of facts, etc. from related parties,
collection of materials, or other necessary fact-check investigations by the whistleblowing contact
person as instructed by the chair if the chair considers that the behavior in question is less wrongfulor that it is necessary in terms of keeping the content of the disclosure confidential.
3. Paragraphs 2 through 6 of Article 13 and Article 14 shall apply mutatis mutandis to the mattersnecessary for the investigations in the main clause of the preceding paragraph, and Article 13-2 andArticle 14 shall apply mutatis mutandis to the matters necessary for the investigations in the provisoof the same paragraph.
4. Upon receiving a report from the Whistleblowing Committee, the Chancellor must, in light of thetruth, falsity, and seriousness of the content of the complaint, institute measures necessary to ceasethe disadvantageous treatment against the Whistleblower and restore it to a state complying withlegal requirements and institute measures necessary to prevent its recurrence.
(Prohibition on Searching for Whistleblowers)
Article 18.
1. Beyond-Minimum Sharing and search for Whistleblowers by any of the Trustees and the Faculty,
Staff, and Other Members of the Corporation are prohibited.
2. Each Whistleblower may lodge a complaint to the Whistleblowing Committee via thewhistleblowing desk if he or she becomes aware that Beyond-Minimum Sharing and search for the
Whistleblower has occurred or could have occurred.
3. If a complaint is lodged in accordance with the preceding paragraph, the Whistleblowing
Committee shall promptly investigate the truth, falsity, etc. of the details thereof. However, suchinvestigations may be substituted by the findings of hearings of facts, etc. from related parties,
collection of materials, or other necessary fact-check investigations by the whistleblowing contact
person as instructed by the chair if the chair considers that the content of the complaint is minor orthat it is necessary in terms of keeping the content of the disclosure confidential.
4. Paragraphs 2 through 6 of Article 13 and Article 14 shall apply mutatis mutandis to the mattersnecessary for the investigations in the main clause of the preceding paragraph and Article 13-2 andArticle 14 shall apply mutatis mutandis to the matters necessary for the investigations in the provisoof the same paragraph.
5. Upon receiving a report from the Whistleblowing Committee, the Chancellor must, in light of thetruth, falsity, and seriousness of the content of the complaint, institute measures necessary to cease
the search for the Whistleblower and restore it to a state complying with legal requirements andinstitute measures necessary to prevent its recurrence.
(Disciplinary Actions and Other Dispositions)
Article 19.
The Chancellor shall institute appropriate measures such as disciplinary action or other disposition inaccordance with the provisions separately prescribed by the Corporation against each faculty or staff

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member who has engaged himself or herself in Wrongful Conduct, disadvantageous treatment against
one or more Whistleblowers, Beyond-Minimum Sharing, or search for one or more Whistleblowers.
(Follow-up)
Article 20.
1. After processing a Whistleblowing Disclosure, the Chancellor shall ensure that Wrongful Conduct
has not recurred and that rectification measures and recurrence prevention measures are functioning
adequately, and shall institute new rectification measures and recurrence prevention measures asnecessary.
2. The Chancellor shall conduct adequate follow-up to protect each Whistleblower by checking
whether or not the Whistleblower is suffering or at risk of suffering disadvantageous treatment orworkplace harassment on the grounds that he or she blew a whistle, whether or not BeyondMinimum Sharing or search for the Whistleblower has occurred or could occur, and otherwise
checking the situation.
3. If the Chancellor judges that the reputation of one or more related parties is damaged afterinvestigations by the Whistleblowing Committee in which nothing is found to prove the facts
alleged in a Whistleblowing Disclosure, the Chancellor may institute necessary measures to restore
the reputation of the related parties, such as publicizing the actual facts.
(Exceptional Steps in Case that Whistle is Blown on the Chancellor)
Article 21.
1. In the case that a whistle is blown on the Chancellor or otherwise the Chancellor is involved in areportable case (hereinafter referred to as the "Chancellor-Involved Case"), the Auditors shall takeone of the following responses.
(1) Monitor the case and require reports on the findings of investigations and other necessary mattersby requiring progress reports, etc. on the responses to a Whistleblowing Disclosure, etc. by thechair (including a member who performs the chair's duties on its behalf in accordance with
Paragraph 6 of Article 10; the same applies in this article) or the whistleblowing contact personin accordance with Articles 12 through 18 and Article 20.
(2) make investigations themselves or establish an investigation committee comprised of outside
professionals and investigate the case.
2. If the Auditors consider that the investigations by the chair or the whistleblowing contact person
are not adequate, the Auditors may instruct the chair or the whistleblowing contact person to makeadditional investigations and make investigation themselves, or establish an investigationcommittee comprised of outside professionals and investigate the case.
3. If the Auditors consider that the investigations by the chair or the whistleblowing contact person
are adequate, have made investigations themselves, or have established an investigation committee
and investigated the case, the Auditors shall report to the Board of Trustees on the findings of theinvestigations and other necessary matters. The report must be made to the extent that does notinterfere the proper performance of work and the protection of secrets, reputation, privacy, etc. of8the person(s) who committed Wrongful Conduct and other persons involved in the case.
4. Notwithstanding Articles 14, 15, 17, 18, and 20, the following shall apply to the ChancellorInvolved Case in addition to the preceding paragraphs.
(1) The reporting to the Chancellor under Article 14 shall not be required.
(2) The rectification measures, recurrence prevention measures, and other necessary measures to beinstituted by the Chancellor under Articles 15, 17, 18, and 20 shall be instituted by the chair.
(Exceptional Steps in Case That Whistle is Blown on Trustees or Other Executives)
Article 21-2.
1. In the case that a whistle is blown on a Trustee (who is not the Chancellor), President/Principal,
Vice-President /Vice-Principal or otherwise any of them is involved in a reportable case, Paragraphs
1 through 3 of the preceding articles shall apply mutatis mutandis.
2. In the case of the preceding paragraph, "the Auditors shall take one of the following responses" inParagraph 1 of the preceding article shall be read as "the Auditors may take one of the following
responses," and "shall report to the Board of Trustees" in Paragraph 3 of the preceding article shallbe read as "shall report to the Chancellor and the Board of Trustees."(Notification)
Article 22.
The Corporation must notify each Whistleblower of the receipt of a Whistleblowing Disclosure, thedecision on the acceptance or non-acceptance thereof, the findings of relevant investigations, and theoutcome of relevant rectification measures without delay and to the extent that does not interfere theproper performance of work and the protection of secrets, reputation, privacy, etc. of the person(s)who committed Wrongful Conduct and other persons involved in the case. However, this does not
apply to the case of whistleblowing on an anonymous basis or where the relevant Whistleblower(s)cannot be identified.
(Elimination of conflicts of interest)
Article 23.
The whistleblowing contact person, the members of the Whistleblowing Committee, the members of
the investigation team, and all others involved in a Whistleblowing Disclosure may not participate in
the processing or the discussion and implementation of rectification measures of the Whistleblowing
Disclosure with which they are associated.
Chapter 4. Miscellaneous Provisions(Relationship with Other Regulations)
Article 24.
The regulations listed in the following items shall be applied prior to these regulations unless a whistle
is blown on the reportable fact defined in Article 2, paragraph (3) of the Act.

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(1) Sophia School Corporation Regulations Concerning Prevention of Harassment(2) Bylaws for Investigation Procedures for the Unauthorized Use of Research Funds at Sophia
University(3) Bylaws for Investigation Procedures for Misconduct in Research Activities at Sophia University(4) Eiko Gakuen Junior and Senior High School Regulations Concerning Prevention of Harassment(5) Rokko Junior and Senior High School Regulations Concerning Prevention of Harassment(6) Hiroshima Gakuin Junior and Senior High School Regulations Concerning Prevention ofHarassment(7) Sophia Fukuoka Junior and Senior High School Regulations Concerning Prevention ofHarassment(Publicity and Training)
Article 25.
The Corporation shall keep the executives and the Faculty, Staff, and Other Members of the
Corporation and the students of the schools established by the Corporation fully informed of theworkings of the whistleblowing disclosure response system and the importance of compliance, by
methods including active publicity through bulletins, websites, etc., periodical training activities, andinformation sessions.
(Regular Evaluations and Inspections)
Article 26.
1. The Corporation shall evaluate and inspect the whistleblowing disclosure response system on aregular basis and improve the system as necessary.
2. Necessary matters for the implementation of the evaluation, inspection and improvement under thepreceding paragraph shall be decided by the Whistleblowing Committee.
(Retention of Records)
Article 27.
1. The Corporation shall cause the whistleblowing contact person to create a record of responses toWhistleblowing Disclosures and appropriately store the record for 20 years together with therecords/materials related to received Whistleblowing Disclosures and the record of theirbrowsing/sharing history.
2. Measures necessary to prevent the leakage of sensitive information shall be taken for the record in
the preceding paragraph, such as minimizing the number of persons who may browse/share it andrecording its browsing/sharing history.
(Public Notice of Operational Status)
Article 28.
1. The Chancellor shall give public notice inside the Corporation of the number, etc. ofWhistleblowing Disclosures reported by the Whistleblowing Committee or the whistleblowing

10contact person.
2. The public notice under the preceding paragraph shall be given to the extent that does not interfere
the proper performance of work and the protection of secrets, credibility, reputation, privacy, etc.
of the persons involved in the relevant case.
(Reporting to Administrative Organs)
Article 29.
Articles 16 (Protection of Whistleblowers), 18 (Prohibition on Searching for Whistleblowers), 19(Disciplinary Actions and Other Dispositions), and 20 (Follow-Up) shall apply mutatis mutandis toeach case that any of the executives and the Faculty, Staff, and Other Members reports to one or moreadministrative organs (meaning the administrative organs defined in Article 2, paragraph (4) of theAct) with the authority to impose a disposition (meaning an order, revocation, and other acts involving
the exercise of public authority; the same applies hereinafter) or make a recommendation, etc.
(meaning a recommendation and other acts which are not dispositions) on Wrongful Conduct at the
Corporation.
(Miscellaneous provisions)
Article 30.
1. Matters necessary for Whistleblowing Disclosures other than those stipulated in these regulations
shall be stipulated by the Whistleblowing Committee.
2. Other clerical work in relation to Whistleblowing Disclosures shall be performed by the Audit
Office.

Supplementary provision
These regulations shall become effective on April 1, 2009.
Supplementary Provision
These regulations shall become effective on April 1, 2011.
Supplementary Provision
These regulations shall be revised and become effective on April 1, 2012.
Supplementary Provision
These regulations shall be revised and become effective on April 1, 2014.
Supplementary Provision
These regulations shall be revised and become effective on April 1, 2016.
Supplementary Provision
These regulations shall be revised and become effective on October 1, 2022.
Supplementary Provision
These regulations shall be revised and become effective on November 9, 2022.
Supplementary Provision
These regulations shall be revised and become effective on April 14, 2023.

Note: The English translation is provided for information. The original Japanese version
remains the sole official version. If there is any discrepancy between the two versions,
the Japanese original should take precedence.

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