Value Creation Story

Business Overview

ESG Activities

Corporate Information

Compliance
KOITO aims to continue being a company that is trusted by all stakeholders and declares in the KOITO Group CorporateBehavior Charter that “we will comply with all applicable laws and regulations and will engage in fair, transparent, andfree market competition, as well as proper trade, and responsible procurement,” and “in our global corporate activities,
we will also comply with international rules and local laws, respect local culture and customs, and maintain soundrelationships with government and government agencies.” KOITO has identiﬁed reinforcement of “compliance” as one ofour materiality. To foster an organization and atmosphere to place importance on compliance, the entire KOITO Group iscommitted to engage in compliance activities.

Compliance Management Structure
To strengthen our compliance system, KOITO has established the Compliance Committee, Compliance Promotion Ofﬁce,
Internal Audit Ofﬁce, and whistle-blowing desk (Corporate Ethics Consulting Desk). The Compliance Committee meetsregularly to conﬁrm and follow up on the action plans and results of the Compliance Promotion Ofﬁce and the Internal
Audit Ofﬁce, the operational status of the Corporate Ethics Consulting Desk, and responses to risks.
Personnel in charge of compliance are also appointed at the domestic and overseas subsidiaries to strengthen
compliance and grasp the compliance status in close collaboration. In this way, KOITO promotes compliance-relatedinitiatives in the entire Group.

●Anti-corruption Initiatives●Prevention of Anti-competitive Practices

Through establishing the “Antimonopoly ActRegulations” and implementing internal education
periodically, KOITO is working to prevent corruption, suchas bribery, extortion, fraud, embezzlement, money
laundering, conﬂicts of interest, illegal ﬁnancing topolitical parties and facilitation payments.
The penalties imposed in the event of violations of laws
are stipulated in our internal regulations.
Nobody in the Group was ﬁned or dismissed forcorruption in FY 2022.

Through establishing the “Antimonopoly ActRegulations” and implementing internal education,
KOITO is working to prevent anti-competitive practices,such as market division, price-ﬁxing, abuse of dominantposition and dumping.
When KOITO employees come into contact withcompetitors, we conduct ex-ante and ex-post reviews toensure that they do not engage in conduct that may
violate the Antimonopoly Act.
With the attendance of Audit and Supervisory Board
Members, the Internal Audit Department conducts annualaudit to departments concerned with the Antimonopoly
Act and Subcontract Act, and the ﬁndings are reported tothe Compliance Committee. If any problems were foundduring the audit, the details of the improvement are also
reported to the Committee.
The penalties imposed in the event of violations of laws
are stipulated in our internal regulations.
Nobody in the Group was ﬁned or dismissed foranti-competitive practices in FY 2022.

Reinforcement of Compliance●Fostering Compliance Awareness
KOITO strives to foster employee awareness of compliance by distributing a portable “Ethics Card”
to all employees so that the KOITO Group Corporate Behavior Charter can be a behavior standardfor employees. We also conduct an annual Corporate Ethics Survey for all employees to gauge thelevel of awareness, understanding, and implementation of the KOITO Group Corporate Behavior
Charter. Results of the survey are reported to the Board of Directors and Compliance Committee.
According to the results of the FY 2022 survey, awareness of the KOITO Group Corporate Behavior
Charter was 97%, and employeeʼs ratio who “act to gain customersʼ satisfaction and trust,” “complywith relevant laws and internal rules,” and “respect human rights” all accounted for 100%,
maintaining a high level of awareness, understanding and implementation.

●Compliance Education●Prevention of Harassment

KOITO provides compliance education in the job-rankbased and theme-based training in various ﬁelds, such as
the Antimonopoly Act, the Subcontract Act, andharassment for employees. Compliance training byoutside instructors is also provided to Directors,
Corporate Ofﬁcers, Deputies and Managers.
In addition, KOITO also provides compliance education
to suppliers. We are asking suppliers to ensure complianceat the annual procurement policy brieﬁng session.

KOITO regularly conducts harassment surveys for allemployees. In the survey, subordinates evaluate thebehavior of supervisors (managers such as department
managers and section chiefs, as well as management
supervisors such as subsection chiefs) in the workplace.
Supervisors assess the differences between theirperceptions and evaluation results, and work to prevent
harassment by formulating and posting “My Pledge toEliminate Harassment.”

Strengthening Compliance in the Supply Chain
In order to further strengthen our fair procurement activities, KOITO periodically holds “Compliance training session” foremployees of relevant administrative divisions and business partners (subcontractors and others). In FY 2022, a total of
314 people participated in this training, and we are working to improve their knowledge of procurement activities.

Whistle-blowing System
KOITO has established “corporate ethics consultingdesks” inside and outside the company which allows
employees to report or consult on compliance andharassment issues. After investigating all cases reported
or consulted, we are taking appropriate measures andreport them to the Board of Directors and the Compliance
Committee.
When operating the Corporate Ethics Consultation
Desk, we take thorough care of human rights, such asprotecting the privacy of whistle-blowers and consultants
and preventing disadvantages, so that users can reportand consult with peace of mind. The penalties for
disadvantageous treatment of whistleblowers are clearlystipulated in our internal regulations.

■Number of consultations received(cases)
50

KOITO INTEGRATED REPORT 2022

4142403363032120252210060■Inside consultation desk
■Outside consultation desk

20182019

2020

2021

2022(FY)

KOITO INTEGRATED REPORT 2022 61