Policies and Regulations

Thorough Enforcement of the Compliance System

OLC Group Compliance Code

The OLC Group has established the OLC Group Compliance Code, which sets forth rules for executives and employees on corporate ethics and legal compliance.

OLC Group Compliance Code (Established April 2006)

All OLC Group executives and employees will adhere to the highest ethical standards in compliance with the law and social norms, and will act upon the following codes.

 

  1. Make safety the primary concern.
  2. Respect human rights and prevent discrimination and harassment.
  3. Be fair and transparent in all interactions.
  4. Protect all confidential information, including personal data.
  5. Take resolute action against anti-social elements.

Business Guidelines

The OLC Group has put together business guidelines for all its directors and employees as part of its commitment to the highest standards of corporate conduct in all of its dealings.
Based on the underlying values of integrity and sincerity, the Business Guidelines clarify the need for each and every employee to make a dedicated effort to put into practice their commitment to compliance in all aspects of their work.

Outline of Business Guidelines

  • Give safety top priority (deadline management, workplace safety/environment/health management, overtime work, etc.)
  • Respect human rights (prohibition of engagement in child labor and forced labor, ensuring that publicity activities are in consideration of human rights, prohibition of all kinds of harassment, etc.)
  • Ensure fair transactions (fair selection of suppliers, compliance with the Antimonopoly Act and Subcontract Act, prohibition of bribery, etc.)
  • Ensure information management (management of personal information, protection of intellectual property, precautions in using social media, etc.)
  • Address anti-social elements appropriately (with resolute behavior and actions)

Management Structures

Compliance Committee

The OLC Group has established a Compliance Committee chaired by an individual appointed by the President to ensure the legality of all OLC Group dealings and embed the spirit of compliance in every business function. Any time the OLC Group becomes aware of a serious incident involving improper executive or employee conduct or a violation of laws, regulations or company policy, this committee will conduct the necessary investigations and report to the chairman of the committee, the President and an auditor. In addition, all incidents related to compliance are periodically reported to the Compliance Committee, the President, the Executive Committee and the Board of Directors. We have also established a counseling room for compliance that serves as a contact point for employees wishing to report any instances of improper conduct within or without the OLC Group. In order to ensure the effectiveness of this whistleblower/consulter contact point, internal regulations clearly specify that whistleblowers and consulters shall not receive unfair treatment.

Actions and Performances

Compliance Seminars

The OLC Group provides annual training on compliance-related issues so that all our employees understand and are aware of their legal and ethical obligations, and is engaged in ongoing efforts to monitor and evaluate compliance with our compliance policies and procedures. Additionally, we make sure that our training is appropriate for employees in different positions by introducing seminars with external lecturers, e-learning and group discussions.

Moreover, for several years now we have been holding seminars for all managerial staff, taught by external lecturers. At these seminars, attendees reflect on how one's own organization would deal with compliance issues, both inside and outside the company, investigating problems and drafting action plans.

Questionnaire Survey on Compliance

A questionnaire survey of employees is periodically conducted to monitor the status of compliance at fixed points in time as well as identify any violations.