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 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 FY2023, there were 6 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)

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).

How to report or consult about violations using the Pigeon Partners Line

[Points to note, etc.]

• Information received will be reviewed and investigated from a fair and equitable standpoint, and the results of the investigation reported to the reporting individual. To make this possible, please ensure that when using the Pigeon Partners Line you provide your name and contact details.
• Please refrain from reporting information that defames or denigrates an individual who is not connected with a compliance violation.
• Personal information concerning a reporting individual is disclosed to only the minimum number of persons who need to know in order to verify and investigate the reported information, and is not disclosed to any other persons. Also, unless the reporting individual’s consent is received, the reporting individual’s personal information shall be used only when making further inquiries of the reporting individual and providing a response to the reporting individual. Please report or consult with us if you agree with the Personal Information Utilizing Guidelines(Please click here).
• The Company shall reply only to the reporting individual. However, this does not apply where it is evident that contact has been made on behalf of the reporting individual’s employer.
• The Company shall not disadvantage a reporting individual or the reporting individual's employer on the grounds of having provided information.

[Contact Methods]

Please send an email or letter to the following addresses.

Internal
Senior Manager Legal Dept.
Pigeon Corporation
4-4, Nihonbashi-Hisamatsucho Chuo-ku, Tokyo 103-8480
Email:
pigeon_partners_line(a)pigeon.com
*Please convert (a) to @ upon sending an email.

External
Pigeon Partners Line
C/O City-Yuwa Partners
Marunouchi Mitsui Building 2-2, Marunouchi 2-chome, Chiyoda-ku, Tokyo 100-0005
Email:
pigeon_partners_line(a)city-yuwa.com
*Please convert (a) to @ upon sending an email.

(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 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 2023, we provided employees with training with a focus on the internal reporting system and the Compliance Policy. Through the training, all Group employees learned how to utilize the new internal reporting system launched in 2023 in reference to our own created materials and deepened their understanding of the Compliance Policy through case studies. 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 to employees of the Company and all domestic Group companies on the theme of the Group’s internal reporting system and the Compliance Policy, with an eye to instilling the compliance that employees should practice in their daily work.

(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 2023, we conducted compliance monitoring, and tabulated and analyzed the results for the entire Group and for each Group company. Based on the results for the entire Group, we identified issues such as the lack of knowledge about the internal reporting system including the details of the protection given to whistleblowers, as well as the tendency to prioritize business performance. Accordingly, we will examine and implement specific compliance measures to be implemented in and after 2024 to raise employees’ awareness and understanding about the internal reporting system and the importance of giving priority to compliance.

Information Security Measures