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 March 2023, in response to recent changes in compliance, we revised this code 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 2023, 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.
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 chaired by an individual appointed by the President to ensure the legality of all the 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 Chairperson of the committee, the President, 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 FY2023, no serious legal violations occurred.

We have established a contact point for employees wishing to report any instances of improper conduct including any types of harassment and improper information management within or outside the OLC Group.
We also offer such contact points for each employment category and the OLC Group company to make it easier for employees to seek counseling for any potential issues.
Furthermore, we also provide a dedicated contact point for 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 FY2023, we received a total of 670 reports. These reports varied in nature, with 67% concerning human relations and communication, 20% about personnel systems and working conditions, 9%. involving violations of laws and rules, and the remaining 4% 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.