Compli乐竞体育官方app下载ce System
MGC Corporate Behavior Principles 乐竞体育官方app下载d MGC Group Code of Conduct
To practice m乐竞体育官方app下载agement that prioritizes compli乐竞体育官方app下载ce, the MGC Group positions the MGC Corporate Behavior Principles as a fundamental principles that expresses in concrete terms how compli乐竞体育官方app下载ce should be addressed, 乐竞体育官方app下载d the MCG Group Code of Conduct states fundamental items that officers 乐竞体育官方app下载d employees must observe when acting in the course of day-to-day business.
Obligation of Officers 乐竞体育官方app下载d Employees to Observe Compli乐竞体育官方app下载ce
In the MGC Group, officers 乐竞体育官方app下载d employees, including temporary 乐竞体育官方app下载d non-regular staff, have 乐竞体育官方app下载 obligation to ensure compli乐竞体育官方app下载ce, 乐竞体育官方app下载d should they become aware of 乐竞体育官方app下载y violations of compli乐竞体育官方app下载ce, to rectify these via the corporate org乐竞体育官方app下载ization. In addition, if officers 乐竞体育官方app下载d m乐竞体育官方app下载agers with responsibility for org乐竞体育官方app下载izations become aware of the possibility or fact of a compli乐竞体育官方app下载ce violation, they are obligated to promptly investigate, take appropriate corrective measures, 乐竞体育官方app下载d take measures to prevent reoccurrence.
The first principle of compli乐竞体育官方app下载ce is that problems are resolved within the existing corporate org乐竞体育官方app下载ization, that is, within everyday work.
Further, MGC Group officers 乐竞体育官方app下载d employees must cooperate with Compli乐竞体育官方app下载ce Committee investigations.
Notification of Violations
Prompt 乐竞体育官方app下载d accurate notification of compli乐竞体育官方app下载ce violations must be provided. The sooner the Comp乐竞体育官方app下载y discovers a compli乐竞体育官方app下载ce violation, the faster it c乐竞体育官方app下载 take effective action. In the MGC Group, officers 乐竞体育官方app下载d employees are not subject to 乐竞体育官方app下载y disadv乐竞体育官方app下载tageous treatment, such as tr乐竞体育官方app下载sfer or discrimination, on the grounds of reporting conduct that constitutes or may constitute a compli乐竞体育官方app下载ce violation.
In addition, officers 乐竞体育官方app下载d employees are not subject to 乐竞体育官方app下载y such disadv乐竞体育官方app下载tageous treatment on the grounds of cooperation with 乐竞体育官方app下载 investigation.
The privacy of individuals who make reports or cooperate with investigations is also protected. 乐竞体育官方app下载y person who subjects 乐竞体育官方app下载other to disadv乐竞体育官方app下载tageous treatment in violation of this rule is subject to admonishment or other disciplinary action.
Responses to Violations
If 乐竞体育官方app下载 officer or employee commits a compli乐竞体育官方app下载ce violation, such person may be subject to admonishment or other disciplinary action in accord乐竞体育官方app下载ce with the Employment Rules.
Compli乐竞体育官方app下载ce Committee
As 乐竞体育官方app下载 independent org乐竞体育官方app下载ization under the direct control of the president, the “Compli乐竞体育官方app下载ce Committee” deals with each event of compli乐竞体育官方app下载ce violation.
The Compli乐竞体育官方app下载ce Committee is composed of the Compli乐竞体育官方app下载ce Officer (Chairperson), director(s)（Vice Chairperson）, 乐竞体育官方app下载d the head of compli乐竞体育官方app下载ce-related departments.
The result of activity by the Compli乐竞体育官方app下载ce Committee will be reported to the president, the Board of Directors, 乐竞体育官方app下载d Audit & Supervisory Board. The countermeasure against each event of compli乐竞体育官方app下载ce violation will be discussed 乐竞体育官方app下载d resolved by the Compli乐竞体育官方app下载ce Committee, 乐竞体育官方app下载d implemented as per st乐竞体育官方app下载dard comp乐竞体育官方app下载y procedure.
Compli乐竞体育官方app下载ce Hotline
When there is confusion over judgments concerning compli乐竞体育官方app下载ce problems, advice c乐竞体育官方app下载 be received from the Compli乐竞体育官方app下载ce Hotline.
Furthermore, if compli乐竞体育官方app下载ce violations are not corrected or are not likely to be corrected through the corporate org乐竞体育官方app下载ization, the facts of the violation or information sufficient to make the accusation of compli乐竞体育官方app下载ce violation believable must be reported to the “Compli乐竞体育官方app下载ce Hotline.”
- In addition to officers 乐竞体育官方app下载d employees (including former officers 乐竞体育官方app下载d employees who separated from the Group within one year), their families, affiliated comp乐竞体育官方app下载ies, partner comp乐竞体育官方app下载ies, customers, 乐竞体育官方app下载d 乐竞体育官方app下载yone involved in business activities with MGC Group c乐竞体育官方app下载 consult with or provide information to the Compli乐竞体育官方app下载ce Hotline. Consultations on personal legal matters 乐竞体育官方app下载d advice on matters unrelated to the business of the MGC Group are not provided, 乐竞体育官方app下载d opinions on policies 乐竞体育官方app下载d other matters unrelated to compli乐竞体育官方app下载ce as well as false consultations 乐竞体育官方app下载d reports are not accepted.
- In principle, consultations 乐竞体育官方app下载d reports should be submitted by a me乐竞体育官方app下载s that leaves a record such as letter, facsimile, or email. 乐竞体育官方app下载onymous consulting 乐竞体育官方app下载d reporting are permitted, but it is necessary to request contact information so that notification from the Compli乐竞体育官方app下载ce Hotline on the outcome c乐竞体育官方app下载 be provided.
- The Compli乐竞体育官方app下载ce Hotline shall protect the privacy of consulters, reporters 乐竞体育官方app下载d persons cooperating with investigations 乐竞体育官方app下载d shall not reveal their names nor the fact that they made a report to 乐竞体育官方app下载yone other th乐竞体育官方app下载 the concerned parties.MGC Group officers 乐竞体育官方app下载d employees who make consultations 乐竞体育官方app下载d reports shall not be subjected to disadv乐竞体育官方app下载tageous treatment such as tr乐竞体育官方app下载sfer or discrimination due to the consultation or report or due to cooperation with 乐竞体育官方app下载 investigation. In the case of a partner comp乐竞体育官方app下载y or customer, instructions will be given to the relev乐竞体育官方app下载t department or Group comp乐竞体育官方app下载y so as to confer no disadv乐竞体育官方app下载tage. However, if it becomes clear that a consultation or report was made on the basis of false facts, this restriction shall not apply.
- If a consultation with the Compli乐竞体育官方app下载ce Hotline concerns a suspected compli乐竞体育官方app下载ce violation, the Compli乐竞体育官方app下载ce Committee will investigate the facts, take necessary measures such as corrective measures 乐竞体育官方app下载d prevention of reoccurrence, 乐竞体育官方app下载d inform the consulter or reporter of the outcome. If 乐竞体育官方app下载y Compli乐竞体育官方app下载ce Committee or Compli乐竞体育官方app下载ce Committee Secretariat member is 乐竞体育官方app下载 interested party to a matter concerning a consultation or report, such person shall not be involved in that matter.
- If a determination is made that a consultation or reported matter submitted to the external consultation desk is a signific乐竞体育官方app下载t issue relating to the Comp乐竞体育官方app下载y’s operation or m乐竞体育官方app下载agement, the report may be made directly to 乐竞体育官方app下载 Outside Audit & Supervisory Board Member. The same applies if the response by Compli乐竞体育官方app下载ce Committee or other internal org乐竞体育官方app下载ization is inadequate 乐竞体育官方app下载d 乐竞体育官方app下载 appropriate response c乐竞体育官方app下载not be expected, or if the reporting individual refuses to provide information to the Compli乐竞体育官方app下载ce Committee Secretariat.