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Fair Operation Practices

Basic Principle

The “K” Line Group stipulates in its Charter of Conduct that it promises to comply with applicable laws, ordinances, rules and other norms of behavior both in the domestic and international community and conduct its corporate activities through fair, transparent and free competition. Aiming to have all employees work with full understanding of the importance of fair business practices, including competition law and anti-corruption, the “K” Line Group strives to establish its compliance promotion system and enlighten the compliance awareness among them by implementing various training programs.

Compliance Promotion System

“K” Line has implemented a Compliance Committee chaired by the President & CEO that discusses the policy securing our compliance system and measures to address compliance violations. To strengthen compliance throughout the organization, the company has appointed a Chief Compliance Officer (CCO) as the individual with the ultimate responsibility for compliance. In addition, “K” LINE and its group companies have established a Hotline System for whistleblowing to promptly detect and rectify possible compliance violations.

Initiatives to ensure compliance

In order to further ensure compliance of the entire group, “K” Line has implemented a variety of awareness-raising activities, such as the notification statement circulated to “K” Line and our group companies, seminars intended for the management of each company, etc.

  • Thorough notification of the importance of compliance with competition laws/anti-corruption laws in each country.
  • Implementation of E-learning and training seminar (percentage of full-time employees taken the courses: 100% by fiscal 2014).
  • Implementation of Stratified compliance training programs
  • Number of Employees taken the program in fiscal 2015: 80 in total
    • New Employees: 15 persons
    • Employees at 11th year: 25 persons
    • Employees at 15th year: 15 persons
    • Newly-appointed Managers: 25 persons
  • Implementation of ”Employee Compliance Awareness Survey" (conducted in fiscal 2014, percentage of employees responded: 95.9%).
  • Implementation of "Compliance Month" (every November.)

Whistle-Blowing System

The Hot Line System

We have introduced a whistle-blowing system called the “Hot Line System.” In addition to an internal contact, we have also appointed lawyers as external contacts. Furthermore, we have appointed full-time Audit & Supervisory Board Members as another contact window independent from business execution. All employees working at “K” Line or at one of the Group companies that participates in this system, regardless of their position or type of employment, are able to use the system. By establishing user-friendly whistle-blowing system, where the protection of whistle-blower is clearly stipulated and a contact for prior consultation is placed, the Company strives to prevent any violation of compliance.

Response to Violations

If an alleged compliance violation has occurred, the issue is submitted to the company’s Compliance Committee. Following the “Detailed Rules for Responding to Compliance Matters,” which sets out the procedures to be followed, the Compliance Committee conducts an investigation and then issues instructions to correct or cease the violation, in the name of the Chairman of the Committee. If necessary, the Committee will report to government authorities and will work out measures to prevent a recurrence. If the issue concerns “K” Line, the Executive Officer in charge of personnel affairs will propose any disciplinary action to be taken under the working regulations. Under the “Rules on Operation of Compliance Committee,” the Compliance Committee is obliged to keep strictly confidential the names of whistle-blowers and the details of deliberations including the name, departments, or any other information that would permit identification of the persons involved in the matter, and permits them to consult with attorneys.

Actions against Corruption and Bribery

Concurrently with the world-wide rise in awareness of anti-corruption/anti-bribery, “K” Line has enacted “Internal Rules for Prevention of Corruption” in November 2013. In addition, in August 2014, the Company has established “General Policy against Bribery and Corruption”, in which it prohibits all forms of bribery and other corrupt conduct intended to gain business advantages and determines that no “K” Line personnel may offer, promise, pay, give, demand or accept any bribe or other inappropriate benefit, advantage or reward in order to obtain or retain business or secure any other improper advantage in the conduct of business.

Furthermore, as a measure to enhance our initiatives against corruption and bribery, in July 2014 “K” Line joined the Maritime Anti-Corruption Network (MACN), a global business network dedicated to achieving the vision of a maritime industry free of corruption. We are taking steps to achieve fair trade as a comprehensive logistics company based on its mainstay shipping business.

Initiatives for protecting personal information

To comply with the “Act on the Protection of Personal Information,” “K” Line has developed a set of privacy policies and a personal information management code. Details of the privacy policies are disclosed on our website. The Company identifies and classifies information that it will handle as personal information. It also undertakes related training and education to further refine its system for protecting personal information.

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