Compliance

In the Charter of Corporate Behavior, the Z Holdings Group stipulates strict adherence to and compliance with all relevant laws and regulations, commercial practices, and social ethics, and sets forth a Code of Conduct as a guideline to its activities. To realize these guidelines, the Z Holdings Group works to promote the adoption of these rules among all officers and employees of the Group, to enhance the compliance system and to improve the compliance mindset.

Compliance System

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 Committee

Z Holdings Compliance Committee

In accordance with the provisions in the Basic Policy for Internal Control, the Compliance Committee is established as a meeting body to oversee the compliance system of Z Holdings Corporation and the Z Holdings Group.
The Committee is chaired by the President and Representative Director and the members include the Co-CEO, the persons in charge of the Corporate Division, Legal Division and Personnel Division. Full-time audit and supervisory committee members also participate as observers twice a year.
The Compliance Committee receives reports from the Compliance Division on the following matters and discusses compliance-related issues.
(1) Compliance activity plan and its progress
(2) Operation status of the whistle-blowing system
(3) Status of compliance activities at Group companies
(4) Matters to be reported as stipulated in other internal regulations
(5) Other reports as deemed necessary

Compliance Training Program

As the first step to enhance employee awareness of compliance-related issues, Z Holdings Corporation, 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 Yahoo! JAPAN, 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.

Structure of Comliance Training Program

・LINE Corporation (“LINE”) provides training on LINE CODE, general compliance, harassment prevention, and diversity and inclusion to ensure that its employees comply with laws and internal rules, and conduct ethical corporate activities. LINE also provides training on the Act against Unjustifiable Premiums and Misleading Representations, FCPA, Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, anti-bribery and Improper Solicitation and Graft Act for some employees who are involved in business activities related to these acts.

Compliance Self-Checks

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.

Internal Reporting System with Three Internal & External Contact Points

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 some contact points can be accessed anonymously. Additional measures have been put in place to protect the whistle-blowers from any negative consequences as a result of their reports. Currently, there are three hotline channels available: compliance division, directors (Co-CEOs, and full-time Audit and Supervisory Committee members) and external law firm.
In fiscal 2020, there were 95 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.