Compliance

The SHO-BOND Group believes that a sound compliance framework is vital to conducting business activities that meet high standards of social responsibility and are capable of sustainable growth. The SHO-BOND Group Code of Conduct enables all employees to do their jobs based on a thorough understanding of socially acceptable behavior, laws and regulations, internal rules and other guidelines.
All employees at the group are dedicated to the achievement of the action principles “Corporate Credo” and the Corporate Philosophy by using a broad range of activities for earning the trust of society and all stakeholders.

Philosophy

A compliance promotion program is in place throughout the Group. The SHO-BOND Group Code of Conduct clearly states the rules of behavior that all employees and executives are expected to follow. We also have a compliance manual to ensure that all employees are aware of the importance of compliance. In addition, we have close cooperation among Group companies by establishing a Compliance Office responsible for compliance matters and assigning a compliance leader to each site.

Further, we provide education and training to everyone in the Group to raise compliance knowledge and awareness.

We hold company-wide e-learning once a year. At the same time, we provide compliance education in training sessions such as new employee training and rank-specific training. The e-learning program explains basic compliance knowledge and the Group’s policies and uses confirmation tests for better retention. In training sessions, we inform participants of the Construction Industry Law as well, which construction companies must comply with.

To prevent harassment, we conduct regular self-checks and e-learning programs to create a comfortable working environment by encouraging each personnel to be aware of the issue.

The Group has internal and external contact points for whistleblowers to report any kind of violation they detect, including harassment, regardless of its agent (individual or organization) and the type of regulations violated (applicable laws, the rules of employment, the SHO-BOND Group Code of Conduct, etc.). The purpose is to investigate and eradicate such violations as soon as we can.

We pay due care so that whistleblowers will remain anonymous as a general rule and will not suffer any disadvantages.

Public works projects account for a large proportion of our Group’s net sales, so ensuring the fairness and transparency of operations is particularly important to us. Regarding the prevention of bribery, we established an Anti-Bribery Policy in August 2022 to clarify our stance on preventing any corruption, in addition to the SHO-BOND Group Code of Conduct, in which stipulating a complete elimination of bribery. To ensure that nobody in our Group becomes involved in bribery, we have established standards for the use of entertainment expenses and are committed to acting ethically according to recipients. We also make all executives and employees aware of the risks of bribery and how to deal with them through training programs.

Based on the SHO-BOND Group Code of Conduct, we will continue to uphold high ethical standards to prevent corruption and continue to ensure fair and sound relationships with our customers and all other stakeholders.

The SHO-BOND Group stipulates the Anti-Bribery Policy as follows based on the SHO-BOND Group Code of Conduct. We will uphold high ethical standards to prevent bribery, and ensure a fair and sound relationship with our customers and all other stakeholders.

1. Compliance with laws and regulations
   Our officers and employees will not only comply with the laws and regulations concerning bribery applicable to all countries and regions that are related to their own duties but will also behave with social decency.
2. Prohibition of bribery
   Our officers and employees will not engage in business entertainment or give money, goods, etc., to anyone to obtain unjust business gains, whether it is in a direct or indirect manner. Furthermore, they will not accept business entertainment, money, goods, etc., that deviate from common sense, and will uphold sound business practices.
3. Thoroughgoing record and storage
   Our officers and employees will accurately keep truthful records related to expenditures in accounting ledgers and other books, and appropriately store such related materials.
4. Execution of education and training
   We will regularly carry out education and training related to the prohibition of bribery and the internal whistleblowing system.
5. Maintenance of a system for consultation, reporting, and whistleblowing
   To prevent and rectify the violation of this policy by our officers and employees, we maintain an appropriate system for consultation, reporting, and whistleblowing. Furthermore, appropriate measures will be taken to ensure that persons who engage in such consultations, reporting, or whistleblowing, or cooperate with such persons, will not suffer any disadvantages.
6. Response to violations
   In the case that our officer or employee violates this policy, we will immediately carry out an investigation of the facts and take disciplinary action that is in accordance with internal regulations, etc.

The Group has established “Eliminate antisocial forces” in the SHO-BOND Group Code of Conduct and stipulated that all unlawful demands by antisocial forces shall be eradicated and relationships shall be cut off.

We recognize that any relationship with antisocial forces, including unlawful demands from them, is a serious compliance risk. We manage risks following the policies and systems set forth in the risk management rules and strive to prevent damage by regular communication with the local police and companies to collect information on antisocial forces.

We also thoroughly educate all officers and employees on eliminating antisocial forces through compliance manuals, company-wide e-learning, and rank-specific training.