Earth Corporation

Compliance

Compliance Structure

To maintain a strong sense of ethics and ensure compliance with laws and regulations, Earth Corporation distributes a pamphlet entitled “Earth Corporation Conduct Guidelines and Explanation of Guidelines” to all employees and officers, including contract, temporary, and part-time employees. The contents of this pamphlet are also posted on the company’s intranet so that all employees are made aware of the importance that the company places on compliance.
We have also established a groupwide Compliance Committee, with the Director in charge of legal affairs serving as chairman, to share information and issues related to compliance, and to promote companywide activities. Compliance Committee meetings were held four times during FY2020.
As rule, twice each month, the Compliance Committee posts the “Compliance Support News,” a compliance-related newsletter issued published by Dai-Ichi Hoki Co., Ltd., on the company intranet to increase awareness of compliance. The Compliance Committee conducts compliance awareness surveys and other activities to appropriately gather and aggregate compliance-related information within the company, and increases the effectiveness of in-house training by selecting divisions to undergo training, creating training contents, making judgments on the timing of training, and reflecting the information gathered.

Outline of the Internal Reporting System

Earth Corporation has established two versions of the “Speak Up Line” (internal and external) as a contact point for internal reporting. Based on this system, employees can submit inquiries about operations or notify the Compliance Committee regarding a possible violation of rules. Reporting to the external contact point can also be done anonymously. The system is accessible to former employees up to one year after they have left the company. Persons submitting inquiries or reports are protected to ensure that they are not subject to any disadvantageous treatment within the company. Three reports were received through the “Speak Up Line” in FY2020.

“Speak Up Line” System

External reporting contact point (for business partners and other parties)

To further strengthen governance functions, Earth Corporation has put in place a contact point to receive inquiries and reports from business partners regarding the company's compliance with laws and corporate ethics (Earth Corporation Conduct Guidelines and Earth Group Global Conduct Guidelines). 
Individuals or business partners that have submitted reports will never be subject to disadvantageous treatment as a result of submitting such a report. (This does not apply, however, in the case of reports submitted for inappropriate reasons, including false reports or slander.)
Whenever possible, we ask that the reporting party include his or her name and company name. Contact point operations are entrusted to IntegreX Inc., a third-party agency that has completed an outsourcing and confidentiality agreement with Earth Corporation (real names and company names are kept within the scope of this third-party contact point; reports to Earth Corporation can be made anonymously.)

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