Simplex Integrated Report 2024
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Compliance and Risk Management StructureAs human capital management and product quality and safety are two of the materiality issues identified, the management structure places particular emphasis on compliance with respect to employee occupational health and safety and cyber security/data security.With regard to employee health and safety, the Health and Productivity Management Committee and the Office Environment Committee have been established under the Sustainability Council to examine specific issues and take relevant measures while complying with laws and regulations concerning occupational health and safety. In addition, the statutory Health Committee and Safety Committee are organized under the Health and Productivity Management Committee and the Office Environment Committee, respectively. The Health and Productivity Management Committee is chaired by a director of the Company who oversees the Health Committee, and seeks the participation of occupational health physicians and employee representatives. As such, under a consistent management system, the Committee plans, drafts, and implements measures that contribute to the maintenance and improvement of the physical and mental health of employees and their family members, and the resulting increase in productivity.For the management of risks associated with cyber security and data security, we have appointed a Chief Information Security Officer (CISO) to manage compliance risks pertaining to compliance with the Personal Information Protection Act and laws and regulations related to economic security. The CISO is also the director in charge of the Group's administrative divisions to serve as a check and balance on the operating divisions. Furthermore, the Information Risk Management Committee has been established as an advisory body for the CISO, consisting of the general managers of each division and other members, to resolve issues based on information collected from the entire Simplex Group in a bottom-up manner.We have established a basic anti-corruption policy and take strict measures to prevent corruption, including the offering of bribes to public officials. We are also committed to complying with laws and regulations concerning fair competition and business transactions, including the Anti-Monopoly Act and the Subcontract Act (Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors).In accordance with the Internal Reporting Regulations, we have established an internal reporting desk operated by an external third-party lawyer as the contact person. In the event of receiving a report of a compliance violation or other incident, we have put a system in place to properly investigate the matter and implement corrective measures to the relevant departments. In addition, the Internal Audit Office, consisting of the head of the Internal Audit Office and seven staff members, conducts internal audits with the aim of enhancing compliance as a company, let alone contributing to the improvement of business performance and the safeguard and utilization of assets.Professional ethicsIn order to ensure compliance, it is important for each and every employee to discipline themselves as a member of the organization under our management philosophy and to fulfill our social mission. We strive to foster compliance awareness so that our employees can act not only in compliance with laws, regulations, and contracts, but also with high ethical standards in accordance with social norms.Fair CompetitionEnsuring effectiveness in compliance with laws and regulationsWith the aim of strictly prohibiting insider trading that violates the Financial Instruments and Exchange Act, we have established Rules for Preventing Insider Trading and strives to ensure thorough information control. With regard to trading of shares by the Simplex Group’s officers and employees, we have established strict periods during which trading is prohibited, and put in place approval procedures and other procedures for trading, as well as training and testing for all employees and business partners.In addition, as part of efforts to prevent bribery and other corrupt acts and excessive business entertainment mainly against domestic and foreign public officials and deemed public officials, we have established a reporting and approval system and conducts anti-corruption training for our employees.We take a resolute stance against antisocial forces and will immediately end any relationship with them as one of our basic policies. In accordance with the Rules for Elimination of Antisocial Forces and the Implementation Guidelines for Background Check for Relationships with Antisocial Forces, we have put in place a system to eliminate transactions and other relationships with antisocial forces. With respect to our business partners, we perform procedures to confirm that they have no relationships with antisocial forces prior to starting business with them and on a regular basis as well. In addition, candidates for officers are also subject to the same procedure prior to submitting a proposal for election to a general meeting of shareholders. We also confirm with employees that they have no relationships with antisocial forces and require them to submit written pledges.For more extensive information, please visit our website https://www.simplex.holdings/en/sustainability/55Management CommitteeChairperson: CEOChairperson: CISORepresentative Director,President and CEOExecutive CommitteeInformation Risk Office EnvironmentSafety CommitteeSustainability CouncilHealth and Productivity Management CommitteeCommitteeHealth CommitteeChairperson: CEOOccupational Health Physician/Staff RepresentativeCompliance and Risk Management System DiagramImplementation of compliance trainingBusiness development mindful of human rightsWe develop our business mindful of human rights. In doing so, we have established a basic human rights policy that sets priority issues based on the results of analysis of the types of human rights that could pose a risk of serious human rights violations in the Group's business activities, as well as the severity of the assumed risk of human rights violations. Please refer to the Sustainability website for details of the Simplex Group Basic Policy on Human Rights.Efforts to Eliminate Antisocial ForcesCompliance

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