Compliance and Risk Management｜HOSHIZAKI CORPORATION

Compliance and Risk Management Structure

The Hoshizaki Group has established the following compliance and risk management structure, which is described in the “Hoshizaki Compliance Handbook”, and disseminated this to all Hoshizaki Group employees.

Hoshizaki shall establish and thoroughly raise awareness of the Hoshizaki Group management philosophy, the Compliance Regulations, and other rules so that the Directors and employees are continually reminded of the need for compliance with laws, regulations, and the Articles of Incorporation in the execution of their duties.
Hoshizaki shall establish the Compliance and Risk Management Committee in order to maintain and improve its internal control system and develop its compliance and risk management structure.
In the event that a Director discovers any violation of laws, regulations, the Articles of Incorporation, etc., such Director shall immediately report the violation to the Audit and Supervisory Committee and the Board of Directors. Group companies shall immediately report to the Corporate Auditor and the Board of Directors, and conduct whistleblowing to the Audit and Supervisory Committee of Hoshizaki Corporation.
A whistleblower system shall be established as a route for reporting for employees who discover any violation of laws, regulations, the Articles of Incorporation, etc.
Hoshizaki shall work to firmly exclude anti-social forces by refusing all involvement with them, confronting any undue demands from anti-social forces in a strong and resolute manner, and coordinating with the police and other external experts.

The “Compliance Regulations” apply not only to Hoshizaki Corporation, but also to the entire Group. In accordance with the Compliance Regulations, a Compliance and Risk Management Committee (hereinafter referred to as the “Committee”) has been established and is chaired by the President and Representative Director of Hoshizaki Corporation. Hoshizaki Corporation’s Legal Department acts as the secretariat of the Committee, and plans and formulates overall compliance initiatives. Moreover, in order to achieve a good result in the implement of the decisions made by the Committee, the Executive Officer in charge of legal affairs has been appointed as the Chief Compliance and Risk Management Officer. In addition, each division and group company has its own Compliance and Risk Management Manager and Deputy Manager.

The Committee has established the following Basic Compliance Policy for the Hoshizaki Group, which is published in the Hoshizaki Compliance Handbook together with the Hoshizaki management philosophy, to serve as a code of conduct for all officers and employees of the Group.

Basic Compliance Policy

The Hoshizaki Group will

Always recognize the importance of the social responsibility and public mission the corporate Group has with respect to food environments and strive to establish unwavering trust from society through sound and appropriate business operations.
Endeavor to proactively and fairly disclose accurate information (product and corporate information), strive for broad communication with society, and devote ourselves to transparent management that can be well received by society.
Strictly comply with laws, regulations, and rules and conduct honest and fair corporate activities that do not violate social norms.
Have a sense of duty as a good citizen and a strong sense of ethics that can be applied to the international community and contribute to the development of the economy and society at home and abroad.
Stand ﬁrm against antisocial forces that threaten the order and safety of civil society and never give way to them.

In addition to the above policies, the Hoshizaki Compliance Handbook also includes the Compliance Regulations, Risk Management Regulations, and Whistle-blowing Regulations, and sets out specific action guidelines and common rules regarding matters such as insider trading controls and harassment prevention.

The Compliance Handbook is distributed in booklet form to all executives and employees of the Hoshizaki Group. It is also used as a text for the Group’s compliance training. It has been translated into 15 languages, including English, and is distributed to all employees at Hoshizaki’s overseas Group companies. Hoshizaki will continue to strengthen compliance by conducting annual compliance training with the participation of all employees.

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Compliance Training

The Hoshizaki Group distributes the Hoshizaki Compliance Handbook to all employees and conducts compliance training at least once per year in order to raise awareness of compliance at Hoshizaki.

In FY2020, in order to further strengthen governance and compliance, Hoshizaki established a Legal Department and switched its system to one in which the Legal Department provides compliance training to manager-class employees at group companies. By adopting a “cascade-down approach”, through which managers who have taken the training teach their subordinates in turn, Hoshizaki aims to simultaneously strengthen the promotion of both manager-learning and worker-understanding.

The content of training focuses on topics where compliance needs to be strengthened in actual operations due to the current situation, and is interwoven with case studies to enhance effectiveness.

In recent years, covered topics such as “harassment”, “labor relations” and “information security” have been covered. Hoshizaki also provides anti-fraud training to sales companies in Japan, specifically covering sales activities. In addition, the Legal Department reviews training materials in advance and brushes up the content to be included in consultation with local staff in order to enhance the quality of compliance training. In the United States and parts of Europe, efforts are being made to make training more accessible by developing training materials with the guidance of specialized providers.

Whistleblower System

The Hoshizaki Group has established a whistle-blowing system. Depending on the nature of the report or consultation, whistle-blowers may choose either an in-house contact point (the Legal Department), or a lawyer who is not an in-house counsel as an external contact point. Each whistle-blowing case is reviewed by the Compliance and Risk Review Committee. Countermeasures are then implemented and the results are reported to the Compliance and Risk Management Committee and the Corporate Management Committee Meeting.

The Compliance and Risk Review Committee is composed of permanent officers and the heads of related divisions, and also reflects the opinions of the Advisory Group, which was established from the perspective of promoting diversity.

Risk Management System

The Hoshizaki Group has determined the following points with regard to risk management. It also identifies and assesses the Group’s risks in an effort to strengthen Group risk management, and plan and execute measures for each type of risk.

The Hoshizaki Group shall set forth the “Risk Management Regulations” as the basis for its risk management system, appoint managers for the management of each type of risk, and establish a risk management structure in accordance with the Risk Management Regulations.
The Board of Directors and other meeting bodies shall monitor the status of risk management and establish an oversight system by coordinating with the Audit and Supervisory Committee and the Internal Audit Department.

Response in the Event of a Major Disaster (BCP)

Each Japan-based company of the Hoshizaki Group has formulated a business continuity plan (BCP). On April 1, 2010, Toyoake City in Aichi Prefecture, where Hoshizaki’s Head Office Factory is located, was designated as an “Area subject to Disaster Prevention Measures against Tokai Earthquake Disaster”. In response, Hoshizaki’s Head Office Factory established a “BCP Formulation System”, a “System to Promote the Operation of BCP Under Normal Conditions”, and a “System for Invoking BCP During Emergencies”, headed by the President as responsible person. It also developed a system for coordinating with neighboring companies toward the early recovery of regional industries in the event of a disaster.

Information Security

The Hoshizaki Group’s information security classifications are outlined in the Information Management Regulations. Information security management is carried out by the Information System Department.

Hoshizaki Group’s sales companies in Japan have each appointed at least one person to promote IT. In addition, a system has been established to prevent information leaks and other risks by alerting the Information System Department in the event of an information security incident.

Hoshizaki has also introduced a 24 hour a day, 365 days a year external surveillance service to counter cyberattacks and promote security measures.

Employee training and enlightenment

As part of compliance training, Hoshizaki provides information security education and training for all employees in an effort to raise their security awareness.

Information security when out of the office

Hoshizaki has adopted a system that allows the tracking of mobiles and other devices through GPS when Hoshizaki employees take these out of the office. If a device is lost, it can be disconnected from the network and the information contained within the mobile device can be erased.

Management of personal information

Personal information is managed in accordance with the separate Privacy Policy.

In accordance with the April 1, 2022 revision of the Act on the Protection of Personal Information, Hoshizaki has revised the Privacy Policy to address the expanded scope of publication. The revised policy was posted on the Hoshizaki Corporation website.

Furthermore, to prevent information leakage, Hoshizaki prohibits the use of USB memory sticks, etc. and collects the history of all e-mails, including attachments, in case of unforeseen circumstances.

Hoshizaki Group has had no serious leaks of personal information to date.

Initiatives to Prevent Corruption

The Hoshizaki Group, in accordance with its internal anti-bribery rules, prohibits all acts of bribery and thoroughly enforces compliance with relevant laws on transactions with public agencies and political donations. Going forward, Hoshizaki will continue to make efforts to prevent misconduct by carrying out anti-bribery training, in addition to education about the Code of Conduct.

Intellectual Property

The Hoshizaki Group endeavors to prevent the infringement of intellectual property rights by having its design and intellectual property departments conduct prior investigations ahead of the launch of products, etc., to ensure that the products, etc., the Group provides do not infringe upon the patents or other intellectual property rights of other companies. In addition, the Hoshizaki Group has concluded advisory agreements with patent offices with expertise in intellectual property laws. It conducts appraisals, etc. to confirm that the intellectual property rights of other companies are not being infringed upon.