Corruption Prevention Initiatives/Compliance

Contents of the Casio Business Conduct Guidelines

1. Developing high-quality products and services and continuing to serve society
2. Careful environmental considerations in all business activities
3. Ensuring fair, honest, and appropriate transaction activities
4. Respecting human rights in all aspects of business activities
5. Respecting employee diversity and fostering supportive work environments
6. Appropriate disclosure of corporate information and constructive stakeholder dialogue
7. Promoting social contribution activities to help realize a sound and spiritually rich society
8. Performing comprehensive risk management of any hazards such as natural disasters, information security breaches, and sudden changes in the business environment
9. Senior management and heads of organizations’ responsibility for setting a good example of leadership by fully observing the Casio Business Conduct Guidelines and ensuring they are completely known to everyone

> Casio Business Conduct Guidelines

Casio recognizes that compliance is the foundation for all corporate activities. Accordingly, Casio believes it is important to win the trust of society by ensuring all of its corporate activities are based not only on legal compliance, but also on high ethical values. To ensure legal compliance in the conduct of business, Casio’s Internal Control Committee inventories relevant laws and regulations and confirms that the responsible departments take appropriate measures to comply. The Casio Business Conduct Guidelines are also made known to all executives and employees.   

In addition, in October 2023, Casio set up the Compliance Office in the Legal Department to serve as an organization responsible for the overall management of compliance. In these and other ways, Casio is always working to ensure legal compliance and foster a culture of integrity. 

Competition Law

We have established the Antitrust Compliance Program and distributed the Compliance Manual to all global sites and are conducting employee education. We are also endeavoring to further entrench this program by carrying out audits on antitrust compliance, reviewing responses to problems identified by audits, and implementing measures. 

In Japan, the Act against Unjustifiable Premiums and Misleading Representations Compliance Committee was established by relevant departments, and awareness promotion activities, including development of self-management regulations and education, are being implemented. Moreover, we are striving to provide guidance through the responsible staff office, share customer opinions and feedback, and share case studies from self-audits and improvements implemented in relevant departments. Going forward, we will conduct regular audits based on the implementation status of education, and further enforce this program.

Privacy Law

As laws and regulations concerning personal information become more stringent globally, in order to promote business using data worldwide, we must adhere to the privacy laws of each country. To this end, in March 2021, we established the Office for Personal Data Protection outside Japan, a dedicated office for addressing global privacy laws. The office works to strengthen compliance structure by tracking legal trends of each country, ensuring the appropriate handling of personal information—from acquiring to storage, usage, and disposal—and conducting employee education and regular audits.

In the conduct of business, Casio’s Internal Control Committee inventories relevant laws and regulations and confirms that the responsible departments take appropriate measures to comply. If any deficiencies are found, corrective measures are taken and regular monitoring is conducted.

Export control, or security trade control, aims to maintain international peace and security. It involves regulations on the export of goods and technology that could be diverted for the development of weapons of mass destruction or other weaponry. The regulations are designed to prevent such goods and technology from reaching countries and regions of concern or terrorist organizations.

In 1987, the Export Control Security Program of Casio Computer Co., Ltd. (a compliance program) was established in order to make sure proper measures are taken to ensure the security of exports. The program has since been continually updated along with changes in the Japanese Export Control Regulation.

Casio has appointed employees responsible for export control in relevant departments as part of an internal system to ensure observance of the program.

As the Exporter Compliance Standards took effect in April 2010, Casio has been striving to maintain and manage its system by conducting voluntary annual audits while ensuring thorough legal compliance, in response to the revision of applicable laws and regulations. Efforts include the strengthening of training activities at group companies in Japan.

Casio has also established a management system for complying not only with Japanese export laws but also with US Export Administration Regulations. The company is working to improve global export management, including the implementation of export management training in fiscal 2013, at group companies in the UK and Germany, and in fiscal 2014 at a group company in the US.

In fiscal 2023, Casio revised its compliance program in line with the revision of Japan’s Foreign Exchange and Foreign Trade Act and shared information throughout the group regarding legal revisions relating to the situation in Ukraine. 

Casio has established a Compliance Committee on Japan's Act against Delay in Payment of Subcontract Proceeds, Etc., to Subcontractors (Subcontract Act) which includes group companies, and is striving to ensure all transactions comply with the law. Under the annual basic plan of the Committee, each group company in Japan implements PDCA cycles. In fiscal 2021, in-house seminar subjects were expanded and made available to all employees. Moreover, employees that deal directly with suppliers and outsourcers are always provided with the necessary knowledge through classes sponsored by the relevant government authorities

In-house training sessions are designed to provide a more concrete understanding by taking actual subcontracting transactions and associating them to specific business operations. Various efforts were made to encourage understanding, such as conducting training sessions with original teaching materials prepared to suit the unique transaction conditions of various group companies.
The Compliance Committee also obtains the latest information from government websites and email notification services, and sends the information directly to committee members. The news is also posted on the committee's website, and shared with the entire group.

In offices where subcontract transactions are handled, independent audits are carried out on an ongoing basis. Casio confirms that proper, compliant transactions are executed, by inspecting the document record of the entire series of transactions from ordering to payment.
Casio will continue to promote understanding of the Subcontract Act among its employees, and work to strengthen its system for even better compliance. The company will strive to promote even sounder transactions and create value with suppliers.

In addition, Casio has announced the “Partnership-Building Declaration,” making clear its approach to co-prosperity among large enterprises and SMEs.

Casio prohibits bribery including restrictions on illegal and improper business entertainment and gift-giving. Still, in light of recent developments including the ongoing globalization of business, the tightening of regulations, and more robust efforts to detect bribery, Casio issued the Casio Guidance on the Prohibition of Bribery (for the Casio Group) in July 2014 and the Manual on the Prohibition of Bribery (for Casio Computer Co., Ltd.) in October 2014 in order to further strengthen the handling of bribery risks throughout the Casio Group.
The Casio Guidance on the Prohibition of Bribery articulates the Group’s basic stance and philosophy on the prohibition of bribery, including the prohibition of facilitation payments. The Manual on the Prohibition of Bribery specifies the structure and mechanisms for the prevention of bribery, including the designation of persons responsible for compliance, education and training, auditing, and the Whistleblower Hotline, as well as specific rules such as a limit on the monetary amount of business entertainment and gift-giving. Additionally, Casio headquarters encourages each site to produce local rules and manuals in an effort to strengthen the mechanisms for the prohibition of bribery throughout the group.

The Casio Business Conduct Guidelines, established in March 2022, clearly mandate zero-tolerance of bribery, and Casio is working to ensure that this policy is thoroughly enforced.

The Casio Group Code of Conduct stipulates that all officers and employees in the Casio Group must comply with international norms, applicable laws in each country and region, and company rules in their daily activities as the Casio Group engages in its global business.
This also applies to tax affairs. The Group strives to maintain its tax compliance by paying taxes appropriately in compliance with each country's tax laws, including transfer pricing taxation and anti-tax haven measures, as well as international rules and other statues.

As a way to ensure compliance, including respect for human rights, and to maintain sound governance, Casio set up a Whistleblower Hotline in April 2006. The hotline has been functioning with neutrality and fairness across all of its internal and external contact points.

Operating on a basis of impartiality, the hotline follows up on all whistleblower reports and consultations, and takes resolute measures against any improper behavior discovered. Effort is put into preventing issues before they grow into real problems.

The contractor operating the external contact point of the Whistleblower Hotline was changed in April 2015. Now Casio employees can utilize online whistleblower consultation and report filing in English and Chinese, and telephone consultation and reporting is also available in English. This has given employees at group companies outside Japan better access to the hotline. To ensure even greater hotline awareness, Casio will strive to further increase group-wide understanding of the system in fiscal 2016, using a special intranet site with information on whistleblower protection in Japanese, English, and Chinese.

In addition to internal hotlines, in fiscal 2018, an external whistleblower hotline was established exclusively for suppliers in October 2017.

In May 2019, the Internet-based external whistleblower hotline was overhauled to comply with Europe’s GDPR and to enable whistleblowers to interact directly with the Whistleblower Hotline Office on a half-anonymous basis (actual name given to external whistleblower hotline but anonymous to the company).

In fiscal 2023, eleven issues were reported to the Hotline. Of these, five concerned harassment, and six had to do with other issues. Seven issues have been brought to a satisfactory resolution.

Earlier, in 2021, Casio changed the operational system to ensure highly appropriate responses to whistleblower reports and requests for consultation. The changes included:
(1) utilizing attorneys to ensure objectivity, confidentiality, and a sense of security at the contact point;
(2) reinforcing appropriate response by the right person in the right place, including experts, while ensuring the confidentiality of whistleblowers, as an appropriate response throughout the handling process;
(3) reinforcing final confirmation in the same manner as above to ensure the confidentiality of whistleblowers and appropriate responses; and
(4) revision of the Basic Rules for the Whistleblower Hotline in conjunction with the change in the operational system.

In January 2022, Casio started to disclose the number and summaries of disciplinary actions within the company.