SII Compliance System

As our CSR committee carries the function of compliance, it has been working on raising compliance awareness and responding to each compliance problem.

Based on the Internal Control Basic Policy, we continue to reinforce and improve the compliance framework of subsidiary companies in the world.
At the overseas subsidiary companies, their appointed compliance coordinators are promoting activities to enhance the compliance framework.

SII Code of Conduct and Action Guidelines

To act in accordance with the SII Group Charter of Corporate Behavior, SII established the SII Code of Conduct, defining the basic requirements that all the SII Group directors and employees need to comply with. We continue to conduct the SII Code of Conduct thoroughly at all sites in the world.

The Action Guidelines were also established in Japan to provide a specific and detailed code of behavior. We continue to thoroughly implement the Action Guidelines at each of our sites in Japan. Each subsidiary outside Japan has established and communicated its own guidelines.

SII Code of Conduct

Compliance Consultation Services

SII has established the SII Helpline and internal Consultation Service, which is staffed by outside attorneys, for the purpose of early detection and correction of noncompliant acts and to help strengthen compliance management.

The SII Helpline is open to all retired employees of the SII Group and its companies, as well as business partners of the SII Group, to provide information on non-compliant activities related to the SII Group.

The contents of the reports and consultations are immediately reported to the Chairman of the CSR Committee and the Corporate Auditors, and also to the CSR Committee and the Board of Directors on a regular basis.

There were one report and consultation in the SII Group in FY 2022.

Compliance Education

In order to ensure compliance from senior management to each and every employee, in FY 2022 we continued to implement an online quiz requiring answers from all executives and employees of the SII Group in Japan.

We also continued to provide compliance awareness training for new employees and senior management, as well as compliance training for each division and affiliated company.

Compliance Awareness Survey

SII continually conducts compliance awareness surveys to check how much the SII Group employees’ compliance awareness has been raised and entrenched. The FY 2022 result is as follows. Some questions have been changed from three options to five options since FY 2022 in order to provide a more detailed understanding.

Results of the FY 2022 Compliance Awareness Survey

Survey Period: June 20 through July 29, 2022
Target: Employees and executives of SII and its affiliated companies in Japan, and temporary employees (optional)
No. of Respondents: 1,376 (1,342 in FY 2021)

Q1 Do you always bear in mind the laws and rules concerning your operations when you are working?

Compliance Awareness Survey

Total may not become 100% due to rounding off.

Q2 Does everyone in your division or department fully understand the importance of compliance with laws and rules?

Compliance Awareness Survey

Total may not become 100% due to rounding off.

Export Control

To ensure international security and proper export control in compliance with laws and regulations, we have established an internal system and conduct regular audits and education. In FY 2022, education continued to combine intranet-based education with face-to-face education. The audits are supplemented by supplementary investigations by the secretariat to confirm that appropriate export controls are in place.
In addition, SII has received approval from Tokyo Customs as an “authorized exporter" under the Authorized Exporters’ Program in recognition of its excellent compliance system and security management.