Basic Views

Recognizing compliance as the foundation of corporate management, the NH Foods Group continues to take steps to ensure a thorough understanding of compliance.

To strengthen compliance Groupwide, we have defined clear guidelines for our management policy in, among others, the NH Foods Group Global Action Standards. In line with these guidelines, we engage in publicity campaigns such as providing compliance training sessions and stage events aiming at promoting compliance awareness, also carefully monitor the effectiveness of our activities and make improvements and corrections as necessary.

Central to this effort is the Plan-Do-Check-Act (PDCA) cycle, which is repeated continuously with the aim of firmly establishing the concept of compliance as an essential component of management.

Compliance Promotion Framework

Important information concerning compliance is centrally managed by NH Foods Ltd.’s Compliance Department which reports in real time to directors, Audit & Supervisory Board members, executive officers, and the heads of relevant departments and divisions and also presents reports to the Board of Directors and Compliance Committee.

Additionally, the Compliance Committee, which is responsible for verifying compliance status and considering compliance policies across the Group, the Compliance Promotion Committees, which advance compliance initiatives at each Group company and business division, and the Compliance Leader Conference, which comprises representatives from the Compliance Promotion Committee of each Group Company and considers specific measures, all coordinate to share the latest information and to work thoroughly toward better compliance management.

Compliance Framework

Global Action Standards

In following The NH Foods Group Global Action Standards, Group executives and employees will cultivate the way of thinking needed to fulfill our responsibility to stakeholders and carry out our work with pride as a member of a global company conducting business activities in Japan and other countries.

Position of Global Action Standards

Each group company is creating own action standards based on The NH Foods Group Global Action Standards depending on each country and region’s social habits and the type of business.

NH Foods Group Action Standards (Japan edition)

Based on the NH Foods Group Global Action Standards, it shows the concrete way of acting in Japan.

All executives and employees respond to the corporate social responsibility and requests from the society by acting in accordance with the NH Foods Group Global Action Standards.

These materials have been translated into six languages, including English and Chinese, to make it easier for non-Japanese employees to understand.

We also periodically review and revise the content.

NH Foods Group Action Standards (Japan edition) [16.8MB / 48 pages]

Holding Awareness-Raising Campaigns

We work to entrench compliance awareness through the entire Group (Including non-regular employees) by leveraging various opportunities to carry out awareness-raising activities.
Compliance training is conducted for each level of employee such as managers, Group company presidents, etc. and involves content such as learning about harassment issues and compliance violations and discussing case studies as a group.

Also, all employees attend Compliance Competitions held at each business location and Group company, which include compliance study sessions and communication promotion activities.
In addition, we are working to prevent harassment by using video materials and handbooks at each business site.

• Compliance Competitions
  Compliance study meetings and communication promotion activities are held at each site, and the results of daily compliance activities are shared.

Number of Participants（FY2022）

Compliance Trainings^* (NH Foods Group in Japan)

1,957 (including 1,625 attendees ranked manager and higher)

Compliance Competitions

17,186

* Total number of attendees for training designed for different levels of the organization, such as new employee training, manager training and Group company president training

Monitoring

We monitor the results and issues arising from our awareness-raising campaigns while also accessing specific feedback and comments from frontline employees for use as valuable information.

Establishing Consultation Channels

We have established consultation channels which all Group employees can access freely in order to share opinions, whistle blow, or seek advice about workplace issues. This includes one in-house channel and two external channels. In 2018, we also established the Auditor Consultation Channel to facilitate the reporting of illegal and illicit activities by Group officers.

We restructured our advice and support systems in 2021. This resulted in the creation of internal and external helplines for matters relating to regulatory compliance, safety, and quality, and another external helpline for general inquiries about workplace problems.

In addition to presenting consultation channel posters at each workplace, all employees (including non-regular employees) are made aware of the consultation channels and provided with portable compliance cards that contain the relevant information.

Additionally, the NH Foods Group Whistleblowing Rules clarify that the identity of whistleblowing individuals should be protected and that unfair treatment toward these individuals is strictly prohibited. All Group employees are made thoroughly aware of these regulations. Employees can also consult or make reports through these channels anonymously.

Response Steps

1. Initial Check

When a report is made, we check if it is anonymous or otherwise confirm the name and workplace of the individual making the report

2. Investigation into the Incident

Once we have the understanding of the individual making the report, we investigate the incident

3. Feedback

We provide feedback to the individual making the report regarding the result of the investigation, response methods, corrective measures, and other matters

4. Resolution

If necessary, we provide support to the relevant companies to implement corrective measures and measures to prevent reoccurrences

Number of Consultations Received (Including Whistleblowing Reports)

The number of consultations was 244 in fiscal 2022.
The main content was about 57% for consultation on personal relations and about 13% for consultation on labor management.
As a result of the reorganization of the consultation desk system in October 2021, the number of consultations has been on the rise.

Identifying Potential Risks Through Regular Visits to Business Sites

The Compliance Department regularly visits business sites to conduct employee interviews on issues such as workplace communication, business issues, and human relations. Through interviews, potential risks are identified and used for early detection, risk avoidance, and prevention.

Responding to Compliance Violations

When there is a report or whistleblowing on compliance issues such as misconduct or harassment in the course of business, we will investigate according to the content. If a compliance violation case is identified and disciplinary action is found to be appropriate, such measures will be taken in accordance with internal regulations.

In addition, if the investigation indicates the need to educate individuals or improve workplace culture, measures will be taken to prevent recurrence.

Anti-Corruption

With regard to the prevention of bribery, the NH Foods Group Action Standards require all officers and employees in Japan to maintain sound relationships with the government and administration. Furthermore, the NH Foods Group Overseas Governance Policy prohibits bribery for overseas Group companies, which are generally considered to be at higher risk than those in Japan. The policy has been translated into eight languages, including English and Chinese, and is disseminated to employees.