麻豆传媒

We conduct annual compliance audits of all departments at headquarters, branch offices, and affiliated companies.
In addition to reviewing compliance initiatives and risk management practices, these audits place particular emphasis on the following:

• Whether there are any workplace culture or communication issues that may discourage the prompt reporting of misconduct or risks
• Whether effective mechanisms are in place to detect and prevent misconduct at an early stage
• Whether the three factors commonly associated with misconduct — pressure (motivation), opportunity, and rationalization — are present

We also conduct comprehensive assessments of a wide range of corruption-related risks, including corruption and bribery, violations of labor standards, and information leakage, as part of our efforts to prevent misconduct and corruption.
In addition, for areas identified as high risk, we verify the implementation of specific risk mitigation measures and promote continuous improvement.

The Company conducts awareness surveys on a continuing basis to confirm employees’ compliance awareness and issues, and to verify the effects of compliance-related initiatives in order to make improvements. In this survey, we have set an evaluation score of 1.0, requiring 80% or more affirmative answers, as our benchmark. Particular weight is given to setting medium- and long-term goals and making systematic efforts to achieve them.

We have compiled and are implementing a Practical Manual for Compliance that presents legal and ethical problems that employees could potentially face in practice. In addition, we have compiled a Practical Manual for International Compliance to serve as a reference point when dealing with issues in other countries, where different laws and customs apply. This version is used at our overseas offices.

We carry out ongoing career-level- and job-function-specific training and e-learning programs for all employees, including harassment education based on actual cases, to improve compliance awareness, eliminate acts of corruption, misconduct, and harassment, and boost understanding and dissemination of the whistleblowing system. As is standard, in FY2024 we provided information regarding our compliance system and the most recent issues involving compliance, including corruption prevention.
Each October, which the Japan Federation of Construction Contractors has stipulated as Corporate Code of Conduct Practice Promotion Month, we conduct training on harassment education based on actual cases and harassment prevention measures for Nishimatsu Group officers, senior employees, and all managerial employees. These efforts serve the purpose of enhancing and maintaining compliance awareness among officers and employees, while also raising compliance awareness among the management class.

The Company established the Nishimatsu Hotline (the Hotline) as a whistleblower contact point to deter misconduct and corruption, promptly address scandals, and improve our corporate culture, and has devised a system whereby all internal and external stakeholders can make reports using their actual names or anonymously.
Reports received via the Hotline are promptly forwarded to the Manager of the Office of President and the Chair of the Compliance Committee. The Compliance Promotion Department, while duly considering the protection of whistleblowers and the confidentiality of information, works with the relevant departments to verify the facts. If the facts are verified as reported, the Company takes the required corrective actions, formulates a recurrence prevention plan, and implements disciplinary action against the employees involved in the misconduct. The results of these actions are then provided as feedback to the whistleblower. Acts that result in disciplinary action will be reported to the Executive Committee Meeting.
The Nishimatsu Hotline is publicized through the Compliance Card distributed to all officers and employees of the Group.

Since fiscal 2016, we have contracted with an outside firm to collect information related to the Company that is posted in social media such as X, Facebook and online message boards. The collected information is checked and analyzed daily.