Code of Conduct

Based on the RACCOON Group’s corporate philosophy and a strong awareness of the RACCOON Group’s social responsibility, we will act as follows with social decency. The officers and executives must thoroughly inform relevant parties of this corporate code of conduct. In the event of a violation of this corporate code of conduct, the president & representative director will lead efforts to resolve the problem, thoroughly investigate the cause, and prevent recurrence as an organization.

1. We will offer safe and quality products and services.
2. We will present quality and descriptions in an appropriate and proper manner.
3. We will engage in fair and free competition with other companies in the same industry.
4. We will ensure that relationships with politicians, political parties, and political organizations remain sound and normal.
5. We will ensure that relationships with national and local government administrative organs remain sound and normal.
6. We will provide corporate information in an appropriate manner where appropriate to business partners, shareholders, investors, etc.
7. We will secure employees’ safety and health at the workplace, and create a comfortable and pleasant workplace.
8. We will strive to improve working conditions for realization of employees’ economic and mental comfort and affluence.
9. We will respect the individuality and human rights of each and every employee.
10. We will take a resolute stance against anti-social forces.

Framework

The RACCOON Group promotes compliance throughout the Group by installing a compliance office, with the president & representative director as the compliance officer and the person in charge of legal operations under the Business Administration Headquarters of RACCOON HOLDINGS as the compliance secretariat. For such matters as acts suspected of violation of laws, regulations, articles of incorporation, corporate ethics, etc., we have installed an internal point of contact for whistleblowing and consultation within the compliance office and an external point of contact for whistleblowing and consultation within an outside law firm to which an audit and supervisory committee member belongs.
We assure that the confidentiality of any person whistleblowing or consulting will be maintained and that they are not subject to mistreatment.

Employee Training

Led by the person in charge of legal operations serving as the compliance secretariat, compliance training is conducted as orientation training upon employment, whether as a new graduate or mid-career hire. The training is conducted in accordance with the compliance manual that has been prepared for employees to acquire knowledge on compliance.
The compliance manual covers matters ranging from what is compliance to the corporate code of conduct, and the standard of conduct providing more specific standards for conduct as workers for enhancing the effectiveness of compliance. In particular, in terms of the standard of conduct, specific standards for conduct and matters to note are presented for each of “clients and business partners,” “society,” “shareholders and investors,” “workplace,” “business operations,” etc. In this manner, we are striving to ensure the understanding of all employees and widespread compliance.

Response to Anti-Social Forces

The code of conduct established in RACCOON Group’s compliance manual is resolutely against anti-social forces and explicitly states that we will have no dealings whatsoever with them.
Specifically, we have enacted “rules against anti-social forces” and established an internal structure for exclusion of anti-social forces led by the head of the Business Administration Headquarters. As the rules prescribe, we carefully decide on new business partners and new transactions with clients, following the Group’s process for checking for affiliation with such forces. We regularly perform the same check on current partners and clients.
In addition, we are a member of the Tokyo Metropolitan Police Department’s Special Violence Prevention Measures Association and, in addition to attending the association’s events such as training seminars, use the association, police department, legal counsel, and other outside specialist institutions to proactively collect information.

Prohibition of bribery

The RACCOON Group considers that establishment/strengthening the structure of prohibiting bribery is an essential task due to worldwide and growing concern against bribery. In the compliance manual, prohibition of bribery (including facilitation payment) such as Japanese criminal law/Unfair Competition Prevention Act, and adherence of the anti-bribery regulations in other countries are stated. Also, in order to adhere to anti-bribery regulations, we maintain records such as approved documents/accounting information, and establish the necessary company structure. As a consultation/whistleblowing desk when any behaviors which violate, or are likely to violate the anti-bribery regulations or compliance manual are found, we have prepared two desks, the compliance office and the outside legal office, where an Outside Audit and Supervisory Committee member belongs.