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, Casio set up the Compliance Office in the Legal Department to serve as an organization responsible for the overall management of compliance. The Compliance Office is working to ensure even more thorough compliance with laws and regulations globally, reform systems, and reinforce the administration of education and internal rules. The office also works to foster a group-wide 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. Executives and employees at all sites worldwide participate in group-wide education, which is primarily e-learning, and all programs maintain a high participation rate.

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 2024, we disseminated information on revisions to laws and regulations related to the situation in Ukraine, and we also brought in external instructors to conduct online training for 100 people, including executives and other people in charge of export control organizations. This training was intended to deepen understanding of Japan’s Foreign Exchange and Foreign Trade Act and when it applies, as well as recent conditions around the world.

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. Going forward, we will take measures to address globalization and the changing times, focusing on countries with a high risk of corruption while considering types of transactions, business partners, and payment terms.

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.

When making donations to political funding organizations, Casio complies with relevant laws and regulations, such as the Political Funds Control Act, and manages donations appropriately through an appropriate decision-making process based on internal regulations.

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 external contact point for whistleblower reports is available in English and Chinese, and is compliant with the EU's General Data Protection Regulation (GDPR). Reports can be received from overseas Group companies while protecting privacy. Global consultations and reports can also be received online (as well as telephone consultations and reports in English) 24 hours a day, 365 days a year.

In order to further familiarize employees with this system and firmly establish it across the Group, we regularly review the system and structure, and we have established a dedicated external contact point for receiving reports from business partners. We have also created a whistleblower reporting system that ensures fair treatment and reliability while guaranteeing the confidentiality of the reporter by assigning staff with specialized knowledge of whistleblower reporting systems and utilizing external lawyers.

In recent years, there has been growing demand for more effective whistleblower reporting systems due to the revision of Japan’s Whistleblower Protection Act in June 2020. Accordingly, we decided to establish a permanent Whistleblower Committee with independence within the company, as shown in the following organizational chart, and we are working to improve the system so that it is easy for those making reports to use by revising internal regulations to clearly prohibit any disadvantageous treatment or retaliatory acts against these reporters and to clarify confidentiality obligations.

In fiscal 2024, five issues were reported to the Hotline. Of these, three concerned harassment, and two had to do with other issues.