Corporate Ethics Guidelines
Based on the “Pigeon 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. The corporate ethics policies declare that every Pigeon Group employee must comply strictly with laws, regulations and social norms, in both letter and spirit, acting in good faith and with a high sense of ethics. The corporate ethics guidelines enable us to earn the trust and support of stakeholders. As the corporate ethics guidelines indicate, we believe it is vital to convey to all Group employees Pigeon's business philosophy and the sense of values of its management. Our President and CEO and all other executives lead by example in rigorously promoting our spirit of ethics and compliance.
The Group's compliance policy is based on the Pigeon DNA and the Pigeon Way as well as the Corporate Ethics Guidelines (corporate ethics policies and the code of conduct), and we have established compliance policies in three areas that are considered to pose a particularly high-risk in the entire Group: “Anti-bribery and Corruption,” “Antitrust Compliance” and “Information Management.”
These policies are designed to promote understanding and action by the Group's employees, as well as promote compliance of the entire Group by outlining specific actions to be taken and the necessary systems and frameworks in these three areas.
- 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.
Compliance Education and Monitoring
With the Legal Department playing a pivotal role, we ensure that all Group employees are knowledgeable about compliance. We carry out training on topics such as the Pigeon DNA and the Pigeon Way, Corporate Ethics Guidelines, and the internal whistle-blowing system at the Company and at each Group company in Japan and overseas. In 2022, we circulated the monthly “Pigeon Compliance Communication” newsletter to employees of the Company and all domestic Group companies on the theme of the Corporate Ethics Guidelines and the Group's internal whistle-blowing system. In addition, as compliance training, all Group employees were informed of the importance of compliance through a video message from the President and CEO. Furthermore, the Pigeon DNA and the Pigeon Way, the Corporate Ethics Guidelines (including anti-corruption and compliance with antitrust laws), and the internal whistle-blowing system were explained based on our own materials, in order to instill the compliance that employees should practice in their daily work. After the training, a questionnaire, utilized to improve the contents, was given to the participants.
In addition, approximately once every three years, we conduct "Compliance Monitoring," in which employees of the Group answer questionnaires in order to evaluate and improve their awareness and understanding of compliance. In the Compliance Monitoring, we check the level of understanding and penetration with regard to compliance (e.g., understanding and sympathy regarding the Pigeon DNA and the Pigeon Way and the Corporate Ethics Guidelines, understanding of the internal whistle-blowing system, etc.), risks (e.g., information management, fraud, harassment, working environment, quality control, intellectual property infringement, etc.), and organizational climate for each company or organization. If any issues are identified, we consider and implement compliance measures to deal with the issues. We are also working to reduce compliance risks and promote compliance awareness among executives and employees of the Group by reflecting the measures on the above compliance system, framework, and training.
The contents and results of compliance training and compliance monitoring are reported to the GHO Risk Management Committee, which reports them to the Board of Directors every year. Moreover, when internal audits are conducted, the Audit Office confirms the penetration and implementation of the Pigeon DNA and the Pigeon Way in order to understand the status of the organization.
Responses When Compliance Violations are Detected or Perceived
When a real or suspected compliance violation is detected or perceived, the Risk Management Committee gathers information and examines the facts about the matter. The GHO Risk Management Committee then makes arrangements to enable the response necessary to resolve the problem in a timely manner.
Internal Whistle-blowing System
The internal whistle-blowing system consists of two channels for reporting compliance violations. Speak-Up Desks are provided for use within the Pigeon Group. The Pigeon Partners Line is for the use of persons outside of the Group, including business partners.
When problems are discovered within or outside the Group, the GHO Risk Management Committee or a person in charge of whistle-blowing, such as an Audit & Supervisory Board Member, responds to the reporting by examining the facts, taking every precaution to protect whistleblowers and consultants. If necessary, the advice of a legal adviser may be sought to weigh the legal propriety of responses and resolutions. For the in-house whistle-blowing system, a reporting system that ensures anonymity and provides language support was introduced in 2023.
Each year, the GHO Risk Management Committee reports to the Board of Directors regarding the matters reported through the in-house whistle-blowing system, the results of the Committee's responses and related information.
Speak-Up Desk (In-house Whistle-blowing System)
We have established Speak-Up Desk so that any executives and employees of the Pigeon Group (including those employees who have retired within one year) who suspect that a violation of corporate ethics, etc. (compliance violation) may occur or is occurring in the course of business activities can report the issue to a Speak-Up Desk or seek consultation about the issue there. Pigeon personnel are advised about Speak-Up Desk and how to use it through compliance training, etc.
In FY2022 the Speak-Up Desk received 5 reports of compliance violations.
The following three lines are available as contact points. For access to the contact point, anonymity is ensured and the system supports the language used by each Group company.
1) In-house contact point (to the Legal Department)
2) In-house contact point (to the Audit & Supervisory Board members)
3) Outside contact point (to a legal adviser)
[What to Report / Seek Consultation About]
Appropriate subjects to report or seek consultation about include bribery/corruption, fraudulent accounting, payoffs, embezzlement, information leaks and other serious violations of the law, as well as violations of corporate ethics, actions likely to damage the good name of the Pigeon Group, or other actions commensurate with the above.
[Protection of Whistleblowers, etc.]
Whistleblowing is handled based on the Pigeon Group in-house regulations, which stipulate whistleblower confidentiality, prohibition of information sharing outside the scope, prohibition of the disadvantageous treatment of whistleblowers or persons cooperating in examinations as a result of such reporting, consultation and cooperation, prohibition of searching whistleblowers, etc.
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)
We have established the Pigeon Partners Line so that any business partner or other person who suspects that a Pigeon Group employee, in the course of business activities with the Pigeon Group, may commit or is committing a violation of corporate ethics, etc. (compliance violation), or has caused suspicion even if the act was not a violation, can use it to report or seek consultation about the issue.
Two contact points are available: An in-house contact point (to the Legal Department) and an outside contact point (to a legal adviser). Our in-house regulations protect whistleblower confidentiality and prohibit the handling of reporting and consultation in ways disadvantageous to whistleblowers or their companies (our business partners).
In FY2022, the Pigeon Partners Line received 1 report of a compliance violation.
Information Security Measures
In delivering products, services and information to customers, we position information security and protection of personal information as issues of vital importance. The Group has established a framework by which the Risk Management Committee deliberates to consider attendant risks and devise countermeasures for each such issue and implement them through the information security sector, legal sector or other sectors with jurisdiction. In this way we are working to strengthen its management of information security and personal information. In July 2005, Pigeon Corporation's framework for protection of personal information was certified with the Privacy Mark. The Privacy Mark system is operated by the Japan Information Processing Development Corporation (now the Japan Institute for Promotion of Digital Economy and Community (JIPDEC)). The Privacy Mark accorded Pigeon certifies that Pigeon is an operator that handles personal information appropriately in accordance with JIS Q 15001:1999, “Requirements for compliance programs for personal information protection,” now JIS Q 15001: 2017, “Personal information protection management systems.” Since JIPDEC certified in 2007, renewed in every two years until 2023.