Governance
Compliance

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

In response to recent changes in compliance, we revised this code in March 2023 to realize “Our Goal for 2030” established in April 2022.
In revising this Code, we have added items related to “environmental initiatives” and “coexistence with society,” which have already been implemented in practice, and further subdivided the content of each item, clarifying its operation and management structure. In addition, we organized the relationship with related policies, such as the human rights policy revised in March 2022 and the procurement policy established in May 2022.

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. We ensure that all employees are informed of the content of the Business Guidelines by making them available on the intranet in accordance with each employment category and role.

We make periodic revisions to the Business Guidelines. The latest revision was made in March 2025, timed with the revision of the The OLC Group Compliance Code. The chief purpose of the revision was to expand items pertaining to the resolution of human rights and environmental issues. In conjunction with the establishment of the OLC Group Basic Policy on Harassment by Customers in 2025 and the OLC Group Basic Policy on Harassment in Recruitment Activities in 2026, we made additions to descriptions of harassment by customers under “Prohibition of harassment.”

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.

The OLC Group has established a Compliance Committee, which is chaired by the corporate officer in charge of the General Affairs Department, to secure the legality of all OLC Group dealings, ensure that the human rights of everyone involved in our business are respected, and embed the spirit of compliance into 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 management and a corporate auditor.
In addition, all cases where consultation is sought are periodically reported to the Compliance Committee, the President, the Executive Committee, and the Board of Directors.
In FY2025, no serious legal violations occurred.

We have established a contact point within and outside the OLC Group for employees wishing to report any instances of improper conduct including all forms of harassment and improper information management.
We also offer such contact points for each employment category and each OLC Group company, regularly informing employees of the helplines via internal posters and on the OLC portal to make it easier for them to seek counseling for any potential issues.
Furthermore, we also provide a dedicated contact point on our website for OLC Group suppliers as a means of identifying, at an early stage, any violation or suspected violation of compliance by an executive or employee of the OLC Group with regard to their relationship with a supplier.
In order to ensure the effectiveness of this whistleblower/consulter system, internal regulations clearly specify their anonymity, and that whistleblowers and consulters shall not be subject to unfair treatment.
In FY2025, we received a total of 681 reports. These reports varied in nature, with 72% concerning human relations and communication, 14% about personnel systems and working conditions, 12% involving violations of laws and rules, and the remaining 2% covering other topics.

The OLC Group provides compliance-related training and education on harassment and proper information management, among others, to all employees upon recruitment and renewal of their employment contract. In an effort to encourage our people to constantly enhance their knowledge and awareness, we also implement, at least once a year, compliance education for employees of all categories in accordance with their respective roles, including seminars and e-learning led by internal and external lecturers, and group discussions.
Moreover, for managerial staff and administrators, we provide practical harassment education based on actual case examples, including engaging them in discussions on preventive measures and hands-on training on dealing with cases that have arisen.

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