Strengthening Our Group Compliance System

The “K” LINE Group Global Compliance Policy (hereinafter, the Global Policy) which was established in January 2017 is to strengthen our Group compliance system on a global level. We oblige all executives and employees in “K” Line and our group companies to comply with the Global Policy. Through holding seminars by dedicated department, distributing Guidebook and activities of dedicated committee, we put much effort into having the Global policy be the guideline on   our daily business for all executives and employees in “K” Line and our group companies.

 

In order to quickly find information related to our management risks at our overseas companies and to manage them uniformly, we established a Global Hotline System (“the System”) in October 2018. We have already established a Hotline system (“the existing system”) for “K” Line and our domestic group companies. Both systems are ensured thorough protection for the reporter and confidentiality regarding the report. Furthermore, in June 2019, we partially revised their rules to improve the systems so that the reporter can more safely ask for advice and make a report.

Our Efforts to Ensure Compliance with Anti-Monopoly Act

Regarding compliance with domestic and foreign competition laws, we ensure that executives and employees comply with the Regulation for Compliance with Anti-Monopoly Act. Furthermore, we are making efforts to ensure compliance awareness concerning competition laws through conducting a continuous training program and promotion of educational activities by the Corporate Legal Risk & Compliance Group. In addition, we conduct audits and monitor the state of implementation of compliance measures. With respect to contacts with competing companies, we strictly enforce regulations on prior reporting and approval depending on the nature of the contact, as well as recording and storing details of each contact.

 

(Main efforts in recent years)

Established “Guidelines on Participation in Meetings and Gatherings Attended by Competing Companies” (October 2012)

Established “Regulations for Compliance with the Anti-Monopoly Act” (April 2014)

Established “Rules Regarding Contacts with Competing Companies” (April 2014)

Set up Fair Competition Promotion Committee (April 2014)

Set up course on Anti-Monopoly Act as part of stratified personnel training (April 2014)

Issued and distributed Guidebook for the Anti-Monopoly Act Compliance (Vol. 1) - Cartel Q&A - (first edition) (May 2014)

Established Audit Procedures (Regulations for Compliance with the Anti-Monopoly Act) (January 2015)

Established Individual Policy of Competition Laws (January 2017)

 

Our Efforts to Prevent Bribery and Corruption

The Global Policy (which includes Individual Policy of the Anti-Corruption Law) established in January 2017 is part of our efforts to effectively strengthen Group compliance to prevent bribery and corruption. Based on the Global Policy, we put much effort into the prevention of corruption and bribery as a member of the Maritime Anti-Corruption Network (MACN), which is a global business network working towards the vision of a maritime industry free of corruption, we are making efforts to prevent corruption and bribery.

 

(Main efforts in recent years)

 

 Established “Regulations for Prevention of Bribery” (November 2013)

 Established “Regulations for Gifts” (January 2014)

 Joined MACN (June 2014)

 Established General Policy against Bribery and Corruption (August 2014)

 Established Individual Policy of Anti-Corruption Law (January 2017)

 Issued and distributed Guidebook for Prevention of Bribery Vol. 1 (first edition) (May 2017)

 

Compliance Promotion System

We discuss our policy for securing compliance throughout “K” LINE and its Group companies, as well as measures for compliance violations, through our Compliance Committee, chaired by the President & CEO. Under the Chief Compliance Officer (CCO), who has the ultimate responsibility for compliance, we are strengthening compliance throughout our organization.

Our Efforts to Raise Compliance Awareness

We set every November as “Compliance Month” when we distribute the President & CEO’s message to executives and employees of “K” LINE and its Group companies to remind them of the importance of compliance. We also hold compliance e-learning training and compliance seminars featuring lecturers invited from outside the company. As part of our stratified personnel training system, we conduct compliance training and hold seminars on individual themes (such as rules for insider trading and harassment prevention) as appropriate. In addition, we distribute the important compliance-related matters in a “Compliance Newsletter” that require particular attention, as appropriate.