Compliance

The Pigeon Group has been implementing compliance-related measures with a focus on the following three pillars. We are examining and implementing these measures to 1) prevent compliance violations and 2) to detect and resolve compliance violations as soon as possible.
The Group’s compliance-related measures are reported annually to the Board of Directors.

(1) Compliance-related rules

Based on the Pigeon Group DNA and the Pigeon Way, the Group has established a basic policy on compliance called the “Corporate Ethics Guidelines.” The Corporate Ethics Guidelines have two components: corporate ethics policies, which comprise the ethical sensibility we must hold to continue to earn the trust and support of society, and a code of conduct, which comprises guidelines that spell out how each employee embodies the corporate ethics policies in business activities. Based on the Corporate Ethics Guidelines, the Group is committed to ensuring that each and every employee complies with all laws, regulations, social norms and their spirit and takes actions with the highest sense of ethics and integrity, thereby earning more trust and support from stakeholders.
Moreover, in the three areas that are considered to pose a particularly high risk in the entire Group: "Anti-bribery and Corruption," "Antitrust Compliance," and "Information Management," we have established "Compliance Policies" that outlines specific actions to be taken and the necessary systems and mechanisms.

Further, in order to detect and resolve compliance violations, we have the following internal reporting systems in place: “Speak-up Desk” (for Pigeon Group employees to make reports through three contact points: the Audit & Supervisory Board Members, the Legal Department, and a corporate attorney) and the “Pigeon Partners Line” (for customers to make reports through two contact points: the Legal Department and a corporate attorney). For the Speak-up Desk, we launched a multilingual reporting system that ensures anonymity in 2023. In the event that a problem is found in or outside the Company, the Risk Management Committee or the person in charge of the internal reporting system, such as Audit & Supervisory Board Members, investigates the facts and responds to the report, giving due consideration to the protection of the person who made the report, and the Risk Management Committee takes measures to prevent recurrence as necessary. When responding to the reports made through the systems, we consult with a corporate attorney as necessary to ensure the legality of our responses and solutions.
In FY2024, there were 10 Speak Up Desk reports and 0 Pigeon Partners Line reports.

Learn more about the Corporate Ethics Guidelines(Please click here).

Compliance Policies

• The Anti-bribery and Corruption Policy clearly states the Group’s position on bribery and corruption, defines the obligations of Group employees, and establishes detailed rules for “Gifts and Hospitality,” “Charitable and Political Donations” and “Agents and Intermediaries.” By adhering to these guidelines and detailed rules in each situation, we strive to ensure thorough prevention of bribery and corruption.
• The Antitrust Compliance Policy sets forth the Group’s position on prohibited acts and risky areas under antitrust laws, defines the obligations of Group employees, and establishes detailed rules including the checklist for “Assessing Antitrust Violation Risk” and the guidelines for “Trade Association Activity and Meeting Attendance” to ensure compliance with antitrust laws.
• The Information Management Guidelines set forth the Group’s information management system and the obligations of Group employees regarding the handling of confidential information and personal information, and establish detailed rules on the handling of “Personal Information” and “Confidential Information” to ensure all of the defined information is managed and protected.

Speak-Up Desk

Speak-Up Desk (In-house Whistle-blowing System)

Operational Flow of Speak-Up Desk (In-house Whistle-blowing System) after Reporting

The Pigeon Partners Line (Contact point for the use of business partners to report or seek consultation on compliance)

[Purpose]
The Pigeon Partners Line has been established as a contact point for reporting or consulting if you have any doubts about whether the conduct of Pigeon Group employees or officers violates corporate ethics, etc. in transactions with the Pigeon Group.

[Protection of reporters]
We will ensure that reporters are not treated disadvantageously in any way because they made a report or consulted and that their personal information will be protected.
Although anonymous reporting and consultation is possible, we may confirm the affiliated company and name of the person making the report or consultation in order to fully investigate the content of the report or consultation and to formulate and implement measures to prevent reoccurrence. However, it is not obligatory to respond to this confirmation.

Please report or consult with us if you agree with the Personal Information Utilizing Guidelines(Please click here)

[When you can report or consult]
When you have any doubt that an act of employees or officers of the Pigeon Group may violate corporate ethics (compliance violation) or may have violated corporate ethics, etc.

[Persons who can use this contact point]
This service is available to companies and related parties that do business with the Pigeon Group.

[Things to keep in mind]
・Please refrain from reporting content such as slander and defamation of individuals unrelated to compliance violations.
・We will not treat the person who made the report or the company to which the person belongs unfavorably because of the report or consultation.

[Respondent of Pigeon Partners Line]
The following person or the division in charge are responsible for handling reports submitted to Pigeon Partners Line :

・Contact point to Legal Dept.:
   Pigeon Corporation Business Strategy Division Manager
   Pigeon Corporation Deputy Division Manager of Business Strategy Division
   Pigeon Corporation Senior Manager of Legal Department
   Pigeon Corporation Legal Section staff

・External Contact Point:
   Corporate lawyer (City-Yuwa Partners)

[Reporting flow]
1) Access the URL of the Pigeon Partners Line website
https://portal.dq-helpline.com/pigeon_partners_line/

2) Enter the common ID and password to log in.
     Common ID: partnersline
     Password:     partnersline

3) Follow the instructions on the website to set your “PIN Code” (except Europe) and enter the details of your report or consultation.

4) Once your report is registered on the D-Quest server, a 13-digit “Report Number” will be issued.

The reporter and the respondent will communicate with each other on this reporting website using the Report Number, and the respondent will make answers such as the investigation results of the report to the reporter. The reporter is also required to have a Report Number when communicating on the website, so please keep it with your report PIN Code.

(2) Compliance education

The Group aims to raise the compliance awareness of all Group employees* by providing them with compliance education based on the Pigeon Group DNA and the Pigeon Way, Corporate Ethics Guidelines, Compliance Policy, the internal reporting system and others at the Company and Group companies in Japan and overseas.
In 2024, we provided employees with training, by revising the content to increase the effectiveness of our compliance education based on the results of compliance monitoring conducted in 2023. Specifically, we clearly showed the management team’s commitment to always giving priority to compliance to all Group employees through a video message and also made explanations about compliance in an easier-to-understand manner by using case studies to help employees address compliance with ownership. After the training, participants were asked to reply to a questionnaire survey, and the results have been utilized to improve the content of our compliance education and training. In addition, we circulated the monthly “Pigeon Compliance Communication” newsletter that focuses on the Corporate Ethics Guidelines, related laws and regulations and internal rules to employees of the Company and all domestic Group companies, with an eye to instilling the compliance that employees should practice in their daily work.

*All Group employees include full-time employees, temporary employees, contract employees, part-time employees.

(3) Compliance monitoring

In addition, by regularly conducting compliance monitoring for all domestic and overseas Group employees, we identify and analyze compliance risks in the Group. We then reflect the results in the compliance rules and education described above, aiming to reduce compliance risks of the Group and raise awareness toward compliance of the employees and executives of the Group.
In 2024, as stated above, we enhanced the content of the training in reference to the results of compliance monitoring conducted in 2023, gave feedback on the results to each department of the Company and each Group company, thereby helping the departments and Group companies identify issues and formulate and implement measures to solve the issues.

Information Security Measures