Basic Concept and Promotion System

The JVCKENWOOD Group understands that compliance requires companies to go beyond simply observing laws and regulations and to also address issues of great public concern stemming from rapid changes that have yet to be dealt with in legislation. Accordingly, we have established “Complying with laws and regulations and engaging in sincere and responsible behavior” as one of our behavior guidelines, and the Compliance Committee headed by the CEO and the Internal Governance Office are leading company-wide efforts aimed at ensuring full compliance in keeping with the JVCKENWOOD Group Compliance Code of Conduct.

Compliance Code of Conduct

The JVCKENWOOD Group Compliance Code of Conduct (established in March 2010) has been promulgated among all executives and employees within the Group through pamphlets (available in three languages) and an Intranet site. Employees at affiliate companies under the Group’s purview are being familiarized with the Standards by Compliance Officers selected by the Board of Directors.

We check the status of compliance with the JVCKENWOOD Group Compliance Code of Conduct from time to time and respond to inquiries from employees and others.

Specific Initiatives to Promote Compliance

Comply with Compliance Code of Conduct

The JVCKENWOOD Group has established “JVCKENWOOD Group Compliance Code of Conduct” and other rules and regulations, as well as a system for monitoring the compliance status of the entire Group’s compliance standards through the Compliance Committee and the Legal Compliance Office. In addition, we annually review the effectiveness of the compliance standards based on the status of revisions to relevant laws and regulations. To prevent compliance violations, we have installed a whistle-blowing system and conducted compliance training to foster awareness of compliance throughout the Group. In the event of a suspected violation of the Compliance Code of Conduct, anticorruption, or other corporate ethics, the department in charge of investigation promptly investigates and takes appropriate corrective actions according to the  content of the violation. Corrective measures are reported to the whistleblower, the name of the person concerned is not disclosed, and only the content is disseminated within the company to prevent the recurrence of similar cases. There were no cases of legal or compliance violations at JVCKENWOOD in FY2021.

Anti-corruption initiatives

Under the supervision of the Board of Directors, the JVCKENWOOD Group clearly states in the JVCKENWOOD Group Compliance Code of Conduct and its internal rules that it prohibits all forms of bribery and corruption and that no illegal or inappropriate means should be employed that may be used to influence the actions of others.

The JVCKENWOOD Group clearly states in the JVCKENWOOD Group Compliance Code of Conduct and its internal rules that it prohibits all forms of bribery and corruption and that no illegal or inappropriate means should be employed that may be used to influence the actions of others. The Group complies with anti-corruption laws and regulations and prohibits bribery and inappropriate benefits such as gifts and entertainment that are contrary to laws, regulations, and social conventions. The Compliance Committee looks into major incidents of noncompliance, such as bribery and corruption, and discusses measures to prevent their recurrence. All incidents of misconduct, including bribery and corruption, are reported to the Board of Directors. There were no legal actions related to corruption taken against us in 2020. We also place importance on ensuring transparency of our corporate activities, and will continue to disclose information, including donations to specific political parties and organizations (political donations made in FY2020: 0 yen).

Internal whistle-blowing system

JVCKENWOOD has two whistleblower systems – a whistleblower reporting system (Helpline) and an auditing informer system – available in Japanese and English to all executives and employees (including contract employees) anonymously. In fiscal 2021, we added the JVCKENWOOD Helpline to our internal reporting system, in which helpline staff serve as contact points. The JVCKENWOOD Helpline consists of two parts: a telephone helpline and an online reporting system, operated by an external whistleblowing service company, which acts as a third-party contact. (Available in Japanese, English, Chinese and Korean)

In the event of concerns about corporate ethics in general and compliance, such as human rights violations, harassment, and all forms of corruption (embezzlement, bribery, etc.), the system will be directly reported to the Internal Reporting System (Helpline) established in the Internal Control Office based on the Internal Reporting Rules and corrective measures will be taken under the leadership of the Compliance Committee. When accounting or auditing concerns arise, employees may use the auditing informer system set up at the Audit & Supervisory Board Office to directly report these. Both systems employ a dedicated communications system run by selected personnel to protect the notifier’s name and maintain the confidentiality of the report. We will continue using both systems to detect and rectify compliance violations (behaviors that deviate from social norms) at an early stage.

Compliance training

Education on compliance is principally the responsibility of the Internal Governance Office, which endeavors under the CEO’s guidance to thoroughly inform all executives and employees on compliance matters in order to construct a robust compliance structure. New employees are provided with training in face-to-face sessions while other employees are provided with regular training through e-learning on the Intranet. In compliance training through e-learning on the Internet, we also conduct an employee’s survey to check the level of compliance awareness and understanding of the Code of Conduct, and gather opinions on compliance activities. In the 4th survey in 2020, 3,057 employees responded to the survey, confirming that their awareness of compliance has been increasing year by year since the survey began.

Compliance Officers conduct annual training for division heads under their direct supervision and other executives. The training is on the topics covered by the Compliance Activity Standards and other related regulations as well as on the prohibition against facilitation payments and bribery of foreign officials, prevention of corruption, such as giving or accepting excessive gifts, corporate scandals and the whistle-blowing system. A cumulative total of approximately 9,000 executives and employees took part in compliance training during FY2020. 

In addition, for the purpose of raising awareness of compliance, we have been distributing an e-mail magazine about compliance to employees once a month since FY2018, and posting and updating compliance-related content on the Intranet. The newsletter also includes compliances news and easy-to-understand explanations of compliance violations that have occurred around the world. It also features columns and case studies to raise awareness of the importance of compliance. Furthermore, we have regularly post compliance-related content to our intranet.

The Board of Auditors’ Commitment on Compliance

At JVCKENWOOD, the Board of Corporate Auditors is responsible for the management audit function, including the detection of fraud, evaluation of internal controls, and monitoring legal compliance. The term of office of corporate auditors is stipulated as four years by the Companies Act, and they are periodically rotated when their terms of office expire. Corporate auditors conduct fair and impartial audits from an independent standpoint.