© ES-CON JAPAN Ltd.
Sustainability
Reinforcing Corporate Compliance
Ensure Compliance
Ensure Compliance
Based on the "Corporate Ethics Code of Conduct," which expresses the practice of corporate ethics and the effectiveness of corporate social responsibility (CSR), we have revised our "Compliance Code of Conduct" as a code of conduct to ensure that all employees of the group act in compliance with laws, social norms, and the articles of incorporation, and the Board Director has resolved and established a "Compliance Declaration."
Furthermore, Compliance Office, which was previously located directly under the President, was reorganized into Compliance Department in April 2025, expanding its functions and structure. This department is overseen by a Compliance Officer and works to clarify the management stance on legal compliance throughout ES-CON JAPAN Ltd. entire Group, while continuing to thoroughly strengthen the promotion of compliance management.
ES-CON JAPAN Ltd. group has established various regulations concerning "prevention of bribery and corruption," "ensuring fair competition and addressing conflicts of interest," and "severing ties with anti-social forces," and we are committed to thoroughly preventing bribery and corruption in all forms.
Addressing compliance violations
If a compliance violation is discovered, an investigation will be conducted promptly under the direction of the Chief Compliance Officer (CCO). If the investigation reveals a violation of laws and regulations, the CCO will report to President and Representative Director and the executive officer in charge of the relevant department (or the president of the affiliated company). The person responsible will be dealt with strictly in accordance with the "Employment Regulations" and "Disciplinary Action Guidelines," measures will be taken to prevent recurrence, and all officers and employees will be reminded of the importance of taking precautions. After a certain period, the CCO will review whether the recurrence prevention measures are functioning appropriately and take additional measures as necessary.
In fiscal year 2025, there were no compliance violations that would have a significant impact on the management of ES-CON JAPAN Ltd. group.
About the internal reporting system
To promote compliance throughout the Group, ES-CON JAPAN have established a Compliance Hotline, which serves as a consultation and reporting point in accordance with the Whistleblower Protection Act and is headed by the Compliance Officer.
Those eligible to report* can report or consult about matters deemed problematic from a compliance standpoint (including compliance with laws, corporate ethics, internal regulations, bribery and corruption prevention, and human rights violations), including harassment. This service is also available to dispatched workers and those who have left the company within the past year. All reports and consultations received are handled appropriately, with investigations and fact-checking conducted as needed, while ensuring the confidentiality of the information. Furthermore, it is also possible to use the "Chubu Electric Power Group Joint Helpline" provided by Chubu Electric Power.
※
-
①
Executives and employees of ES-CON JAPAN Ltd. group
(Director, Executive Officer, full-time employees, contract employees, part-time employees, seconded employees, dispatched employees, etc.) -
②
Individuals (freelancers, etc.) who have a direct contract with ES-CON JAPAN Ltd. group.
(Contractors working within group companies, individuals engaged in specific contracted work, etc.) -
③
Executives and employees of our client companies
(Those who belong to companies that have contractual agreements or other business relationships with ES-CON JAPAN Ltd. group) -
④
Those who previously fell under categories ① to ③ above (within one year of resignation or contract termination)
(Those who have retired, or whose outsourcing or business contracts have ended within the past year)
<Protection of whistleblowers>
-
●
Confidentiality and protection of personal information
The personal information and reports we receive will be shared only with the minimum number of people necessary for the investigation and response, and will be managed with strict confidentiality. *In investigating the facts, we may verify information to the minimum extent necessary, but we will take the utmost care to protect your privacy so as not to lead to the identification of the person who made the report. -
●
Strictly no detrimental treatment (internal disciplinary action may be taken).
We guarantee that you and your business partners will not be subjected to any adverse treatment for reporting or seeking advice. This is strictly prohibited by our company regulations, and any employee who violates them will be severely disciplined.
Anti-bribery and anti-corruption measures
ES-CON JAPAN Ltd. group builds fair and transparent relationships with all stakeholders (customers, business partners, shareholders, local stakeholders, domestic and international politicians and public officials, etc.) based on our "Compliance Code of Conduct" and "Anti-Bribery and Corruption Regulations." We are committed to refraining from all forms of corruption, including bribery, embezzlement, breach of trust, and conflicts of interest, as well as from any actions that could be misinterpreted both internally and externally.
[Training and Information Sharing]
To ensure the effective implementation of this policy, we strive to thoroughly inform and raise awareness among all group employees through posting it on the company intranet and conducting training sessions at least once a year.
[Monitoring and Supervision System]
Under the direction of the Chief Compliance Officer (CCO), Compliance Department proactively monitors the status of bribery and corruption prevention. The CCO reports to the Board Director at least once a year on the operational status, whether any violations have occurred, and compliance with the "Compliance Code of Conduct" and the "Bribery and Corruption Prevention Regulations." Director then evaluates and supervises the system based on this report.
Ensuring fair competition and addressing conflicts of interest in business dealings.
ES-CON JAPAN Ltd. group operates under the philosophy that "all business partners are partners in carrying out our business, and we cultivate mutual trust through fair and just transactions." We strive to build fair relationships with our business partners by complying with antitrust laws, importation laws, and other relevant regulations.
Furthermore, we have established rules regarding conflicts of interest to ensure fairness in transactions.
Specifically, when a conflict of interest occurs between Director or Executive Officer and the company, the matter is submitted to the Board Director, where discussions and deliberations are held, taking into full respect the opinions of Outside Director regarding its rationality, appropriateness, and soundness, before deciding whether or not to proceed with the transaction. Furthermore, when transactions occur with major shareholders, decisions are made to ensure that the transaction level does not deviate from that of transactions with third parties.
Furthermore, conflict-of-interest transactions between our company and ES-CON JAPAN Ltd. subsidiaries and investment corporations, which are financial instrument business operators, are conducted in accordance with the "Interested Party Trading Regulations" and under strict checking rules to protect the interests of investors.
Severing ties with anti-social forces
(1) Basic principles for eliminating anti-social forces
As part of ES-CON JAPAN Ltd. group's efforts regarding anti-social forces, our "Corporate Ethics Code of Conduct" declares that we will not have any relationship with anti-social forces or organizations. Furthermore, our "Compliance Code of Conduct" stipulates that we will take a firm stance against anti-social forces and will not be involved in any illegal or anti-social activities, nor will we provide or receive any benefits, including economic benefits, from them.
Furthermore, we have established a "Guideline for Dealing with Anti-Social Forces" to ensure thorough internal communication regarding our policy on dealing with anti-social forces. We also stipulate that we will work in cooperation with the police and other relevant agencies to firmly and thoroughly eliminate any unreasonable demands made by anti-social forces or organizations.
(2) Dealing with antisocial forces
To maintain the effectiveness of the above, for any new business partners ES-CON JAPAN Ltd. group enters into, we conduct a soundness screening by a third-party organization in advance to confirm that they have no ties to anti-social forces before proceeding with transactions and contracts.
Basic policy on customer harassment
ES-CON JAPAN Ltd. group has adopted the "Chubu Electric Power Group Basic Policy on Customer Harassment," established by Chubu Electric Power, as ES-CON JAPAN Ltd. basic policy in order to ensure a safe and secure working environment for all officers and employees, as well as to build even better relationships with customers and business partners.
