Compliance Initiatives

Basic Stance on Compliance

The CTC Group regards compliance as one of its most important management issues, and is strongly aware that thorough, group-wide compliance forms the foundation for running and managing the Group. By ensuring that each and every Group employee observes all laws, regulations and internal company rules required in the execution of corporate activities, and carries out those activities in a highly ethical and responsible manner in accordance with social norms and morals, we aim to ensure that we are held with esteem and trust by society as a consistently fair, highly transparent, sound and healthy corporate group; and seek to increase the corporate value of the entire CTC Group.

Click here to see more details of "CTC Group Code of Conduct", the Group's basic guidelines for implementing compliance management and fulfilling its corporate social responsibilities.

Compliance Promotion Structure

To ensure thorough compliance at CTC Group, we have established "CTC Group Code of Conduct" and internal company rules, have appointed the Chief Compliance Officer (CCO), and have established the Compliance Committee that acts as an advisory body to the CCO. We aim to enhance the functionality of these organizational structures through the appointment of overall compliance management supervisors responsible for specific business groups at CTC and CTC subsidiaries, as well as compliance supervisors responsible for individual divisions and/or teams.
These compliance supervisors check the progress of their organizations' compliance initiatives on a quarterly basis, and report to the Compliance Committee. In addition, we seek to ensure that compliance awareness is thoroughly instilled by holding ongoing educational training sessions for corporate officers and employees.


Internal Reporting and Consultation Systems

The CTC Group has established internal reporting systems that enable corporate officers, employees, and business partners to report and consult regarding compliance violations. There are two reporting routes, (i) internal point of contact, and (ii) external point of contact. Both routes include provisions to protect privacy of reporters and to ensure appropriate management of reports, and we guarantee that such reporters will not suffer any detriment or disadvantage as a result of an internal reporting. In addition, employees may use employee consultation services.

The number of internal reports and consultations for the CTC Group in the past three years is shown in the table below.

Appropriate responses to all reports and consultations are pursued in cooperation with relevant division as deemed necessary. No serious violations have occurred in the CTC Group.

2021 2022 2023
Internal Reporting *1
(External point of contact)
Employee consultations *2 26 34 13
Total 37 50 30
  • *1The numbers of Internal Reporting include both internal and external point of contact.
  • *2The number of Employee consultations is concerning workplace environments such as harassment.

The members who deal with internal reporting and employee consultations attend workshops arranged by a lawyer, to improve their skills and enhance their abilities on annual basis.

In this way, we continue to operate and maintain the Internal reporting system and the Employee Consultation in an appropriate manner.
In addition, we are focusing our energies into reducing and preventing compliance violations.

Compliance Awareness Surveys

Every other year, the CTC Group conducts anonymous questionnaire-based surveys, “Compliance Awareness Surveys,” of all of its corporate officers and employees, in order to ascertain the actual state of penetration of compliance awareness, and to verify the effectiveness of initiatives. In fiscal 2022, 15,787 people were surveyed, and 14,160 people were responded to such Surveys. The results of such Surveys are analyzed and utilized in formulating, implementing and improving our compliance measures.

Compliance Training and Thorough Circulation of Compliance Information

The CTC Group recognizes educational training as one of the most important action items to be implemented in order to ensure thorough compliance. We seek to ensure that compliance awareness is properly instilled in each and every one of our corporate officers and employees-including contracted/outsourced employees and personnel-by conducting regular training every year, as well as other initiatives to ensure that compliance-related knowledge is made thoroughly known by all.

For instance, we conduct e-learning for CTC Groups’ employees and workshops for new and existing corporate officers.

In addition, the materials regarding on compliance issues are disclosed within the company intranet. So that each department may voluntarily hold study meetings.

Moreover, we conduct awareness-raising activities by disseminating e-mail magazine and video training materials (compliance micro-learning) that are provided by compliance team.

Response to Laws and Regulations

The CTC Group has created a framework for maintaining the most recent information and thereby ensure thorough compliance with laws, regulations, and guidelines,. We have also established our own CTC Group Law & Regulation Guidelines to indicate laws and regulations to which CTC group company should confirm. These guidelines are posted on the CTC Group intranet to which enable employees to read and check at any time.
The departments in charge of each related laws and regulations cultivate the necessary awareness to ensure compliance through posting of related material and manuals on the intranet, e-learning and workshops for new managers. These departments also make reports to the Compliance Committee regarding the current status of compliance within the organization.
We also check the status of practical implementation of such measures within these departments through internal audits, and seek to ensure that proper operational management is being conducted to ensure a more appropriate response to laws and regulations.

Response to Ensure Fairness in Transactions and Prevent Corruption

The CTC Group has established its own "CTC Group Policy on Fair Trade and Prevention of Corruption".
Based on this policy, the Group works to prevent violations of laws and regulations through the establishment and appropriate operation of relevant internal rules, and engages in sales activities in accordance with sound business practices and commonly accepted social norms. The Group also periodically monitors the state of its compliance with relevant laws and regulations, and the operational state of its internal rules, and works to make continuous improvements. To date, the CTC Group has never been investigated by authorities in relation to acts of collusion, cartel activities or bribery.

Click here to see more details of "CTC Group Policy on Fair Trade and Prevention of Corruption"

Elimination of Anti-Social Forces

The CTC Group has clearly expressed that it takes a firm stand against anti-social forces and organizations that threaten the order and safety of civil society in its "CTC Group Code of Conduct", and is working to make this stance thoroughly known amongst all of its corporate officers and employees.  In addition, there is an internal procedure to check business partners to avoid any relationship with such anti-social forces and organizations.

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