All executives and employees (“We”) of Oriental Land Co., Ltd. and its group companies (“OLC Group”) shall follow the OLC Group Compliance Code in all business contexts as part of fulfilling our social roles and responsibilities as a corporation.

OLC Group Compliance Code
Established in April 2006, revised in March 2023

We follow the highest ethical standards in complying with the laws and regulations of all countries or areas where we operate, and conduct corporate activities with respect for international standards and social norms.

(1)We give top priority to safety.

1.1 Prioritizing safety

We always give maximum priority to ensuring the safety of the services, facilities and products we offer through our business. 

1.2 Occupational health and safety

We seek to create safe and healthy workplaces by preventing long working hours and otherwise appropriately managing workdays, managing employee health, and improving working conditions.

(2)We respect human rights.

2.1 Respecting human rights

We strive to protect the dignity of the people connected to our business by respecting their human rights. 

2.2 Prohibiting discrimination

We do not engage in discriminatory treatment and bullying against people connected to our business, including colleagues, business partners and customers, on the basis of gender, age, race, nationality, language, culture, religion, disability, sexual orientation, gender identity or other characteristics. We do not contribute to or allow such behavior.

2.3 Prohibiting harassment

We do not tolerate any kind of harassment, including sexual harassment, power harassment, or harassment related to pregnancy, childbirth, childcare, nursing care or other factors. 

2.4 Prohibiting forced labor and child labor

We do not tolerate forced labor, child labor or any other types of labor that disregard human rights. 

2.5 Respecting diversity and creating positive working environments

We create positive working environments for all executives and employees by accepting the individual differences and identities of colleagues and associates with diverse backgrounds, and by working together with trust and respect.

(3)We engage in fair transactions. 

3.1 Fair, transparent and free transactions

We promote fair, transparent and free transactions, and do not attempt to hinder such transactions through actions such as restricting competition or abusing dominant bargaining position. When selecting suppliers, we always do so through a fair process, comprehensively considering factors such as management conditions, the quality, cost and delivery lead times of products and services, and sustainability efforts.

3.2 Avoiding conflict of interest

We take steps to avoid conflicts between company and private interests.

3.3 Prohibiting corruption and fraud

We do not engage in corruption or fraud, such as bribery or embezzlement, in any form and to any person. We act with the highest ethical standards, including with regard to gift-giving and entertainment. 

(4)We strictly manage and appropriately use information and assets.

4.1 Corporate assets

We strictly manage and appropriately use tangible and intangible corporate assets, including information assets, in accordance with relevant laws and internal regulations.

4.2 Confidential information

We strictly manage confidential information and do not engage in insider trading or other unauthorized use.

4.3 Personal information

We obtain personal information in an appropriate manner and manage such information strictly in accordance with relevant laws and internal regulations, such as by using it only for legitimate purposes.

4.4 Intellectual property

We strictly manage and appropriately use intellectual property in our business operations in accordance with all manuals and guidelines. We also respect third-party intellectual property rights, and do not infringe upon such rights or engage in unauthorized use.

4.5 Responsible public communication

We understand that any statements made or information shared by us as individuals in any circumstances have the potential to affect the company’s reputation and business. We remain aware that we are members of the OLC Group and engage in responsible conduct at all times when communicating publicly.

(5)We are committed to resolving environmental issues. 

5.1 Sustainable coexistence of the natural environment and society

We seek the sustainable coexistence of the natural environment and society in all of our business activities.

5.2 Measures against climate change and natural disasters

We take action against global warming and climate-related disaster risks by working to contain greenhouse gas emissions in all of our operations through reduced energy consumption and improved efficiency, as well as enhance our resilience by adapting to climate change. 

5.3 Circular society

We strive to conserve limited and valuable resources throughout our operations by reducing waste and increasing recycling, using water resources effectively, considering biodiversity, preventing pollution and engaging in green purchasing.

(6)We fulfill our corporate responsibilities and seek to coexist with society.

6.1 Taxation and accounting

We engage in transparent and appropriate taxation in compliance with laws and regulations. We also establish and operate an effective internal control system, perform accounting appropriately in accordance with relevant laws, accounting standards and internal regulations, and disclose information to all stakeholders in a timely and appropriate manner.

6.2 Communication with stakeholders

We believe in the importance of direct dialogue with stakeholders, and ensure appropriate and open information disclosure and two-way communication. We also gratefully accept opinions and requests from stakeholders and strive to incorporate them into our business.

6.3 Responsible advertising and marketing

We engage in advertising with sound judgment. We use fair and appropriate representations and expressions, and provide easy-to-understand explanations of products and services so as not be misleading to customers. We promote our products and services using appropriate evidence, and do not use expressions that defame our competitors or their products and services.

6.4 Community action programs

We engage in community action programs that focus on the positive development of children, the next generation, to in turn help foster healthy and happy families, regions and communities.

6.5 Relationships with political and governmental bodies and other organizations

We maintain sound and transparent relationships with political and governmental bodies, including political parties and politicians, as well as other types of organizations, and comply with laws and internal regulations on political contributions and donations.

6.6 Exclusion of anti-social forces

We take a firm stance against organized criminal elements that pose a threat to civic order and safety, and refuse any and all demands.

Administration and Implementation of the OLC Group Compliance Code

Scope of application

This OLC Group Compliance Code applies to all executives and employees of the OLC Group. The OLC Group actively encourages its business partners to understand and respect the provisions set out in this Code.

Establishment, revision and abolishment process

The OLC Group has established a Compliance Committee that acts as an advisory body to the president of Oriental Land Co., Ltd. This committee promotes understanding of the spirit of compliance in executives and employees, and confirms adherence to the OLC Group Compliance Code. We are also actively working on compliance initiatives for the entire OLC Group in cooperation with those responsible for its promotion at OLC Group companies.
Establishment, revision and abolishment of the OLC Group Compliance Code shall be decided by the Oriental Land Co., Ltd. Board of Directors after deliberation by the Compliance Committee.

Remediation and internal response

Any member of the OLC Group or its business partners who becomes aware of an actual or potential violation of the OLC Group Compliance Code is expected to report this violation to and consult with their direct supervisor or one of the whistleblower contacts described below. The personal information of whistleblowers and others seeking consultation will be protected and handled in accordance with internal regulations to prevent unfair treatment.

【Whistleblower contacts】
OLC Group executives and employees:
Individual compliance consultation rooms set up both inside and outside OLC 
Business partners: 
Dedicated compliance consultation room for OLC Group business partners

Conduct deemed to violate the OLC Group Compliance Code may result in disciplinary discharge based on employment regulations and other rules.

Responsible department

The OLC Group Compliance Code is overseen by the Compliance Committee Bureau  (of the General Affairs Department, Oriental Land Co., Ltd.), which conducts awareness-raising and education of all OLC Group executives and employees.