Organizational Efforts for Realizing Compliance
Recognizing compliance to be one of the most important management issues, officers and employees including directors are making a concerted effort under the Internal Administration Supervisor to thoroughly enforce compliance.
As an advisory body for the Management Committee, the Company has established the “Compliance Committee,” comprising the President & CEO, Heads of Division, Heads of Business Units, General Managing Officer of the Corporate Planning Division, General Managing Officer of the Human Resources Division, General Managing Officer of the Risk Management Division, General Managing Officer of the Compliance Control Division, General Manager of the Compliance Control Division and external lawyers, that in principle meets quarterly to deliberate the Company's corporate activities from the standpoint of compliance, to verify that the Company's compliance framework is functioning appropriately, as well as to determine various measures to enhance the Company's compliance.
Basic Policies on Compliance
In order to win the satisfaction and support from as many customers as possible and become the best model player in the financial instruments exchange market, the Company upholds its “Corporate Vision,” “Principles of Ethics and Conduct,” and “Global Governance Standard, Compliance,” which articulate criteria of judgment shared across all officers and employees, as its “Basic Policies on Compliance.”
Compliance Program and Compliance Manual
As part of its action plan to enhance the effectiveness of the compliance framework, the Company has established a compliance program and compiled a compliance manual as a practical guidance towards the realization of compliance.
Whistle Blowing Hotline
The Company has established the whistle blowing hotline, which serves as a consultation and reporting system for identifying internal compliance issues in advance, enhancing the flexibility of its self-cleansing function, controlling reputation risk and ensuring the Company's social credibility.
When an officer or employee becomes aware of his/her or someone else's compliance issues, or detects a case that may result in a compliance issue, he or she is required to promptly consult or report to a superior in the reporting line or to the Internal Administrator. If consultation or reporting is deemed to be difficult, he or she may consult or report to the whistle blowing hotline.
Division of Duties among the Compliance Monitoring Divisions
- The Retail Compliance & Operations Support Division has been established to oversee the divisions in the Main Office and branches engaged in retail operations, the Wholesale Compliance Division has been established to oversee the divisions of the Head Office engaged in wholesale operations, while the Compliance Control Division has been established to control the company-level framework of compliance.
- The Company has appointed an Internal Administrator pursuant to the Rules of the Japan Securities Dealers Association to each sales division and branch, and an Internal Administrator pursuant to the Rules of the Financial Futures Association of Japan to the Retail Compliance & Operations Support Division and the Wholesale Compliance Division, to conduct monitoring and provide day-to-day instructions on compliance.
- The Compliance Control Division is responsible for investigating and dealing with incidents that occurs in the course of business, and notifying the relevant authorities, management of information asset risks, etc. The Wholesale Compliance Division is responsible for management and review of nonpublic corporate information, management of conflicts of interest, and reviewing the pricing of stocks and bonds, etc. and trading management.