Approach to Compliance
The OPEN HOUSE Group has established compliance management as one of our most important management issues and is advancing various initiatives. In addition to promoting compliance management, we have established the “Employee Code of Conduct” as behavioral guidelines that all Group officers and employees should follow to realize the Group’s basic philosophy.
In addition to legal and regulatory compliance, the Employee Code of Conduct stipulates our involvement with stakeholders (relationships of trust with customers, and understanding and support of shareholders, creditors, etc.), information management, creation of an environment for employee solidarity and self-growth, care for the global environment, prohibition of involvement with antisocial forces, social contribution activities, etc.
Approach to Corruption Prevention
The OPEN HOUSE Group recognizes that corruption and bribery are material risks which can seriously damage our corporate reputation.
Fraudulent profit sharing with public officials, etc. and excessive giving and receiving of entertainment or gifts with business partners and related parties which can invite suspicion from society are expressly prohibited. We have made this known throughout the Group and work to prevent corruption through our corporate activities.
In our business development, multiple relevant divisions perform comprehensive checks and evaluate and work to prevent the risk of corruption in order to eliminate antisocial forces, prevent money laundering, eliminate corrupt transaction methods, prohibit insider trading, and to evaluate entertainment and gift-giving and donations to politicians and political groups.
System to Corruption Prevention
The OPEN HOUSE group conducts regular anti-corruption audits of all our businesses.
The committee conducts annual audits of compliance with the Code of Conduct for Anti-Corruption, including corruption and money laundering, and reports the results to the Board of Directors.
In addition, the Compliance Hotline, an internal reporting system, has been set up to enable all employees to report violations of laws, internal regulations, and standards of conduct directly to the Legal Department or external lawyers.
To ensure that all employees are fully informed, we have implemented measures to prevent corrupt behavior in general through the Code of Conduct and the Code of Conduct set forth in the Code of Conduct.
This content is made available on the company portal and can be viewed by employees at any time.
Related Financial Penalties, Charges, and Settlements
In 2022, there were no serious legal or regulatory violations caused by non-compliance with rules related to bribery prevention, and there were also no financial penalties, charges, or settlements related to corruption.
Financial penalties, charges, or settlements related to corruption
We do not contribute to political activities aside from contributions to political parties and political fundraising organizations. Furthermore, when we do support the activities of political groups, we do so in compliance with the relevant laws and regulations such as the Political Funds Control Act and the Public Offices Election Act.
Amount of political contributions in FY2021: 36,000yen
In the OPEN HOUSE Group, our President & CEO has overall responsibility for compliance-related initiatives and advances the company-wide compliance system. The Board of Directors is responsible for making decisions on compliance-related initiatives and managing the progress. It also works to improve the compliance system for planning and holding compliance education and training sessions, managing a dedicated hotline for reports on compliance violations, etc. and carrying out other measures.
The consultations and reports to the internal hotline, etc. are regularly reported to the Board of Directors.
We regularly hold educational training sessions on our corporate philosophy, our corporate principles, and our Employee Code of Conduct, as well as training sessions to increase awareness on the prohibition of bribery and the prevention of corruption.
We conducted e-learning training for employees once every quarter, and the percentage of lectures received in the fiscal year ended September 2023 was 100%.Going forward, we will continue to target a 100% participation rate.
To create compliance awareness among our employees, we regularly raise awareness to act in accordance with the Employee Code of Conduct. In addition, by regularly holding employee compliance interviews, we routinely review the efficacy of our code of conduct and code of ethics.
Furthermore, by regularly raising awareness to act in accordance with the items stipulated in the Employee Code of Conduct, we work to create compliance awareness among our employees.
Creating and Operating a Reporting System
Based on the Whistleblower Protection Act, the OPEN HOUSE Group has established a compliance hotline for consultations and reports from our employees and business partners. Representatives of the OPEN HOUSE Group or third-party organizations receive consultations and reports provided by the OPEN HOUSE Group’s employees and business partners. The compliance hotline covers a broad range of consultations and reports, including improper actions with respect to laws and regulations, internal rules, general social norms, and corporate ethics, as well as sexual and power harassment, employment issues, workplace environment issues, bribery, and expensive entertainment.
We have stipulated internal rules, and work to create awareness to ensure that the reporter is not identified while the report is being investigated and that the position of the reporter is preserved. The administration division analyzes the reports and information received, and formulates policies to prevent recurrence through discussion with the responsible division. Therefore, we have a system that is able to address issues as soon as possible.
Furthermore, the Customer Service Office handles reports from the general public. We work to ensure the discovery and prevention of fraud by establishing multiple help desks.
Number and Details of Consultations and Reports (OPEN HOUSE Group Overall)
In the fiscal year ended September 2022, there were 12 reports to the Compliance Hotline, of which five were anonymous.
Depending on the content of the inquiry, we conduct a questionnaire survey, interviews, and other surveys to confirm the facts. Depending on the results, we take corrective measures, such as paying attention to the employee, in order to prevent a recurrence of an improvement in the workplace environment.
Please refer to the following for the number of compliance hotline reports.
|Number of consultations and reports received
|Of which, related to discrimination
|Of which, related to harassment
Providing and Ensuring Product
Safety and Security, and Promoting
Products That Contribute to Solving
Talent Development and Labor
Work-Style Reforms and Promoting
Health and Safety
Respecting Human Rights
Supply Chain Management
Regional co-creation Project
ESG Information Index