Promotion and Reinforcement of Compliance

We will comply with domestic and foreign laws and social norms, and carry out fair, transparent, and free competition, as well as appropriate business conduct.
We established the “K” LINE Group’s Charter of Conduct and under this Group charter we adopt compliance with laws, regulations, and corporate ethics as principles for action for the “K” LINE Group. Additionally, we established the “K” LINE Group Global Compliance Policy (the Global Policy) as more specific guidelines, which all officers and employees must comply with.

The Global Policy, which was established in January 2017, is to strengthen the 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 the dedicated department, distributing guidebooks, and activities of dedicated committees, we put much effort into having the Global Policy be the guidepost of our daily business for all executives and employees in “K” LINE and our Group companies.

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.

Regarding compliance with domestic and foreign competition laws, we ensure that executives and employees comply with Regulations for Compliance with the Antimonopoly Act. Furthermore, we are making efforts to ensure compliance awareness concerning competition laws by conducting training programs and promoting educational activities through the dedicated department. In addition, we conduct audits and monitor the state of implementation of compliance measures. With respect to contact with competing companies, we strictly enforce regulations on prior reporting and approval as well as record and store details of each contact.

(Main Efforts in Recent Years)
• Established the Guidelines on Participation in Meetings and Gatherings Attended by Competing Companies (October 2012)
• Established Regulations for Compliance with the Antimonopoly Act (April 2014)
• Established Rules Regarding Contact with Competing Companies (April 2014)
• Set up the Fair Competition Promotion Committee (April 2014)
• Set up a course on the Antimonopoly Act as part of stratified personnel training (April 2014)
• Issued and distributed the Guidebook for Antimonopoly Act Compliance (Vol. 1) - Cartel Q&A - (first edition) (May 2014)
• Established Audit Procedures (Regulations for Compliance with the Antimonopoly Act) (January 2015)
• Established Individual Policy I Competition Law (January 2017)
• Issued and distributed the Guidebook for Antimonopoly Act Compliance (Vol. 2) (June 2021)

To effectively strengthen measures to prevent bribery and corruption, based on the Global Policy (which includes Individual Policy II Anti-Corruption Law), 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 toward the vision of a maritime industry free of corruption.

(Main Efforts in Recent Years)
• Established Regulations for Prevention of Bribery (November 2013)
• Established Regulations for Gifts (January 2014)
• Joined the MACN (June 2014)
• Established the General Policy against Bribery and Corruption (August 2014)
• Established Individual Policy II Anti-Corruption Law (January 2017)
• Issued and distributed the Guidebook for Prevention of Bribery (Vol. 1) (first edition) (May2017)

In November 2019, we revised the Global Policy with the addition of  Individual Policy III Sanctions & Anti-Money Laundering. We ensure that all executives and employees in “K” LINE and its Group companies comply with regulations regarding economic sanctions, as well as rules and measures for anti-money laundering and the counter financing of terrorism that are applicable to the business of the “K” LINE Group.

(Main Efforts in Recent Years)
• Established Individual Policy III Sanctions & Anti-Money Laundering (November 2019)
• Established Rules for Compliance with the Regulations Regarding Economic Sanctions (November 2019)
 

We revised the Global Policy (with the addition of Individual Policy Ⅳ Data Protection Law) in October 2021, based on the recent strengthening of personal information protection laws and enforcement in each country, and We are reinforcing our initiatives for appropriately protecting personal information.

(Main Efforts in Recent Years)
• Established Rules for Management of Personal Data (April 2005)
• Established Rules for Management of Personal Data in Europe (April 2018) Note: Integrated with Rules for Management of Personal Data in October 2021.
• Established Individual Policy IV Data Protection Law (October 2021)
• Revised Rules for Management of Personal Data (October 2021)

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 important compliance-related matters in a compliance newsletter that requires particular attention, as appropriate.

For prevention, early detection, and correction of compliance problems at “K” LINE and its Group companies, we established the Hotline System for “K” LINE and its domestic Group companies and the Global Hotline System for its overseas Group companies. Both systems ensure thorough protection for the reporter and confidentiality of the report so that the reporter can safely consult and make a report.

Tcompliance successfully completed a certification due diligence review of Kawasaki Kisen Kaisha, Ltd., on February 1, 2017, and updates it annually. Tcompliance has granted Kawasaki Kisen Kaisha, Ltd., a certificate signifying that the Company has completed internationally accepted due diligence procedures and has been forthcoming and cooperative during the review process. Tcompliance certification underscores Kawasaki Kisen Kaisha, Ltd.’s commitment to transparency in international commercial transactions.
Tcompliance Certification ID: TC3172-6090
 

Tcompliance is a globally recognized anti-bribery business organization and leading provider of cost-effective third- party risk management solutions. Members and clients include hundreds of multinational companies headquartered worldwide.
For more details, For more information, visit www.tcompliance.com/.