Corporate Governance

We have established the Basic Compliance Policies in order to fulfill our social responsibilities and to improve social credibility for all stakeholders in relation to SVH Group; our CEO has published the Compliance Declaration to internal divisions and to the public in line with the foregoing. We regard the enhancement of compliance framework as one of the critical management challenges and strive to ensure compliance requirements are always met throughout all companies in SVH Group.

Compliance Declaration

Top Message

The society has changed drastically in recent years. Thus, it is becoming more important to practice corporate management in a fair and transparent manner.
For the purpose of SVH Group achieving sustainable growth and expansion toward the future, we are fully aware that we must not only comply with respective laws and regulations but also act in good faith with a broader understanding of social norms in light of common sense and business ethics.
Thereby, we are now determined to fulfill our corporate responsibilities in the society through successful establishment of fair and transparent corporate management; we have stipulated the “Basic Compliance Policies” in addition to the existing business principles known as “Corporate Conduct Carter.
We hereby declare that all SVH Group officers and employees will abide by the Basic Policies and strive to build corporate culture that fully endorses business ethics.

June 27, 2019

Naoki Morioka

Basic Compliance Policies

(Compliance First)
1. Compliance first, in all circumstances.
(Business Operations)
2. We abide by laws, regulations, and social norms; we play honest and conduct transparent corporate activities; we provide safe and secure products, construction operations, and services.
(To our Stakeholders)
3. We respect our customers, business partners, employees, and shareholders; we act with sincerity; we strive to build a sound relationship of mutual trust.
(Our Attitude toward Antisocial Forces)
4. We take a firm stand against antisocial forces and we shall not have any relations with them whatsoever.
(Duty of Reporting and Whistleblower Protection)
5. We report, without delay, when any erroneous and/or fraudulent act is found; no individual shall be treated in a disadvantageous manner on the grounds of reporting such act.

SVH Group Compliance Framework

For the purpose of steadily promoting compliance initiatives across the companies under SVH Group, we have established “Corporate Conduct Carter,” “Basic Compliance Policies,” and “Compliance Rules” to be adopted as Group regulations; at the same time, we have appointed a Director in charge of compliance matters whose tasks are aimed at establishing, maintaining, and improving SVH Group’s compliance management framework. We also set up the Compliance Committee as an advisory body attached to the Board of Directors.

Compliance Framework Diagram
Compliance Framework Diagram

Exclusion of Antisocial Forces

In response to antisocial forces, we have established a system to ensure full exclusion of antisocial forces by conducting a set of full-scale attribute surveys among existing business partners to confirm that no antisocial forces exist in the realm of relationship; for this purpose, we have revised the “Rules for Breaking Off Relations with Antisocial Forces” established a new “Practical Manual for Checking Antisocial Behavior.” In FY 2019, we conducted an all-out attribution survey among existing business partners (approximately 30,000) to re-confirm that no antisocial forces existed therein.

Internal Whistleblowing System

SVH Group has established the Compliance Hotline (Whistleblower Hotline) as a point of contact for referring and reporting of violations against relevant laws and regulations, company rules, codes of ethics, and other inappropriate acts that may occur at the workplaces. The Compliance Hotline is open to all officers and employees of domestic SVH Group companies and officers and employees of overseas Group companies, as well as outside subcontractors including construction service providers. We have three contact points: The Group reporting desk; the Audit Supervisory Committee Member Reporting Desk; and Outside Reporting Desk, respectively.
We have established a system for proper handling and investigating the information received at such reporting desks, giving consideration to the person seeking reference and/or reporting under the “Whistleblowing Rules,” to ensure such operations being conducted in an appropriate manner.

Internal Whistleblowing System

Compliance Training and Education

We conduct compliance training and education programs to all officers and employees of SVH Group based on a curriculum and methods suited to respective job categories. Also, for the purpose of confirming the status of compliance awareness and the level of understanding on the compliance framework, reviewing the actions taken in the past, and identifying potential incidents of concern, we conduct a set of compliance questionnaires which results are to be analyzed to identity items, business branches, and job types that have not been sufficiently penetrated; such data obtained therein is reflected in our future compliance action plans. We strive to conduct compliance activities that are deemed sustainable and highly effective.