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)
[Contact Points]
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)
(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
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.
