As stipulated in our Charter of Corporate Behavior, strict adherence to and compliance with all relevant laws and regulations, commercial practices, and social ethics is the fundamental principle underlying the business activities of the Z Holdings Group. As a guideline to our activities, we have set forth a Compliance Program. To realize the guidelines, we constantly strive to strengthen our compliance system and enhance awareness of compliance-related issues.
Responsible for ensuring compliance throughout the entire company, the Compliance Committee identifies compliance-related issues as well as collects and collates compliance-related information with an eye to strengthening the compliance system and enhancing compliance awareness.
Compliance Training Program
As the first step to enhance employee awareness of compliance-related issues, Yahoo Japan Corporation (“Yahoo! JAPAN”) and some group companies require all new employees, whether recent graduates or mid-career hires, to take compliance-related training courses. In fiscal 2019, the training was held to 838 new hires.
Comprehension and retention of course materials are reinforced through quarterly compliance education targeting all employees on specific themes such as personal information protection, proper information handling, harassment prevention, and intellectual property rights protection, etc. In addition, compliance training on harassment, anti-social forces, information management, and prevention of insider trading is held for new managers, and harassment training is held for managers.
Yahoo! JAPAN provides surveys to all employees so that they can conduct self-check of their compliance knowledge. The results of these surveys are consolidated by the compliance supervisors for use in pinpointing and resolving compliance issues.
Specialized Training by Departments
More specialized compliance-related training courses designed to meet the specific requirements of individual departments are also offered in Yahoo! JAPAN. Departments handling users’ personal information, for example, are offered courses on legal and regulatory issues related to information security.
Reinforcement and Monitoring via Online Learning
In Yahoo! JAPAN, periodic online compliance education programs are conducted to instill compliance awareness via the intranet.
Compliance Hotline (Internal Reporting System)
We have established a Compliance Hotline that allows whistle-blowing of compliance violations such as violations on laws and regulations and on internal rules. Reception staff both within and outside Z Holdings Corporation and the group companies of the Z Holdings Group strictly respect the privacy of whistle-blowers and the hotline users, and additional measures have been put in place to protect them from any negative consequences as a result of their reports. Currently, there are three hotline channels available: compliance division, directors (president and representative director, and full-time Audit and Supervisory Committee members) and external law firm.
In fiscal 2019, there were 87 reported cases of whistle-blowing. The reported incidents were examined and addressed within each department, and necessary actions such as disciplinary punishments and measures to prevent recurrence have been taken. These results have been reported to the Compliance Committee and the Board of Directors meetings.