Compliance

Fundamental Approach

Hulic has established a Basic Stance outlining its approach for achieving its corporate philosophy and the “Basic Principles of Corporate Conduct," which clarifies the Basic Stance. Additionally, the “Compliance Manual,” which reflects changes in business environment and social trends, is used for common actions that must be followed in the daily execution of duties within the Hulic Group. We understand that ensuring these actions are followed and practiced represents Hulic's basic stance toward compliance, and we are promoting the activities to educate all employees about the importance of complying with laws and regulations, social ethics, and company rules.
Each and every employee will strive to fulfill the trust of every stakeholder and fulfill Hulic's corporate social responsibilities by fully complying with laws and company rules as well as engaging in business activities based on a high standard of ethics.

《Results in FY2018》

  • Compliance seminars for all employees and directors
    No. of seminars conducted: 5 times
    Transmission of information: 12 times

Compliance Promotion System

In accordance with the compliance rules, we have built a companywide system composed of the Board of Directors at the top, the Compliance Committee, executive managing directors in charge of legal affairs and compliance, and compliance officers of each department. The status of activities based on the compliance program is regularly reported to the Board of Directors through the Compliance Committee.
The Compliance Manual requires that employees immediately report compliance issues or possible issues to a compliance officer, who will then investigate the matter as necessary, identify the cause, and implement the necessary measures to prevent future reoccurrences.
In 2018, Hulic had no compliance violations.

  1. Respect for Human Rights and Prohibition of Discrimination and Sexual Harassment
  2. Compliance with Laws and Rules
  3. Carry Out Duties in an Honest and Fair Manner
  4. Proper Handling of Information
  5. Insider Trading Regulations
  6. Avoid Relationships with Anti-Social Forces
  7. Consideration toward Environmental Conservation
  8. Maintain and Encourage the Best Communication Possible
  9. Respect Intellectual Property Rights
  10. Business Entertainment/Gift Giving and Prohibition of Bribery
  11. Ensure transparency and reasonableness of transactions

Compliance Hotline

Our employees are encouraged to report directly to the internal or external Compliance Hotline when they consider it unlikely that appropriate corrective actions will be implemented after they consult with the compliance officers of their departments on matters involving compliance issues, or when they are uncomfortable consulting with compliance officers due to the nature of the issues involved.
The Compliance Hotline investigates issues reported and promptly implements corrective actions by paying due consideration to the privacy of whistleblowers.

  • Internal contacts:Chief of the Corporate Planning Department; an additional female contact was added in 2018
  • External contacts:Law offices (a law office aside from the Company’s affiliated law office was added in 2018)

Compliance Seminar

We regularly provide compliance seminars covering set themes to instill awareness of compliance among all employees. In 2018, we held training on the Stamp Tax Act, handling clerical mistakes, and other such topics. In addition to seminars on these overall themes, we hold theme-based seminars on important themes including Building Lots and Buildings Transaction Business Act and the matter of insider trading, in consideration of compliance specific to real estate businesses. Furthermore, we hold discussions in each department if appropriate.
We also post compliance-related news and Q&As to the Company's intranet once a month. We compile comments on compliance seminnars, obtained through questionnaires, as feedback and reflect them in subsequent seminars.

Compliance Seminars in FY2018

  • Frequency:5 seminars implemented (four times for all employees, once for executive officers), transmission of information 12 times
  • No. of participants:All employees (including temporary staff)

Initiatives for Preventing Corruption

Hulic prohibits any act or suspicious act that leads to corruption with business partners, including public agencies such as the government and local government. We also strictly prohibit any bribery and clearly define prohibited activities specifically that lead to corruption and bribery in the section “Business Entertainment/ Gift Giving and Prohibition of Bribery” of the Compliance Manual. In addition, we conduct compliance seminars for all employees as appropriate to build their awareness on prohibited activities such as giving gifts to public officials and excessive entertainment as well as disseminating Hulic's policy on prohibition of corruption and bribery through the Compliance Manual. Moreover, twice a year, our Legal & Compliance Department checks whether each department is appropriately managing the issues related to business entertainment of interested parties and the acceptance or offering of gifts and bribery, and identifies and assesses risks. Furthermore, employees of Hulic and our business partners are encouraged to report any matters involving compliance issues, including suspected corruption, directly to the Compliance Hotline on an anonymous basis. We made no political contributions in 2018.

Compliance through Outsourcing Contractors

As for outsourcing by the real estate business division, we have made fair trades based on “rules for real estate outsourcing management,” respecting relevant laws and regulations as well as instructions by administrative organizations.
When selecting an outsourcing contractor, we carefully check their past performance and abilities to execute operations, the appropriateness in their business execution system and the clarity of the procedures, the appropriateness of the operation management system, and other necessary matters.
After selecting an outsourcing contractor through this confirmation, the Corporate Planning Department checks the relationship for anti-social forces.

Information Security Management

In an attempt to prevent information leaks, one of the critical risks in relation to the performance of business, we have established an information security management system, and enhanced operation management in accordance with the information management rules included in the information handling regulation. We more strictly check the right of access to the shared server, regulate the use of storage media, and regulate instances where information assets can be taken off-site. In our themed compliance seminars held on a regular basis, we thoroughly teach the significance of information management and information security measures in terms of systems in order to increase each employee's awareness. Additionally, we carry out internal audits to check compliance with company rules on information management.

Chart of Information Security Management System

Privacy Policy

In full respect of the importance of protecting personal information and with the purpose of enhancing society's confidence in our insurance brokerage business, we will properly handle personal information in compliance with the Personal Information Protection Law (the "Privacy Law") and other relevant laws and guidelines, and will take appropriate measures to ensure that personal information is secure. We shall make an effort to conduct training and education for our employees so that personal information will be appropriately handled. We will also immediately respond to any claims or concerns regarding the handling of personal information, and will review and improve, as necessary, our provisions for the handling and safeguarding of personal information. In addition, there were no accidents or cases regarding leakage of personal information in fiscal year 2018.

Counteracting Anti-Social Forces

In line with the content of our Compliance Manual, we have put in place a set of Rules for Counteracting Anti-Social Forces to ensure that any contacts with such groups are excluded. Stating that Hulic "has no business relations or relations of any other kind with anti-social forces," the rules lay down as a fundamental approach that relations with anti-social forces are to be excluded.
Additionally, a supervisory department has been set up to promote implementation at the organizational level and a range of measures has been introduced to deal with anti-social forces, including creation of relevant in-house structures, measures to ensure employee safety, and coordination with specialist external bodies.

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