Internal Control System

Basic policy

The AMADA Group has established the AMADA Group Management Philosophy and the AMADA Group Corporate Code of Conduct as common standards for the Group. Furthermore, it has established the Internal Control and Risk Management Committee to ensure that the basic policies of its internal control system are well-known to all employees and to maintain and improve its internal control, compliance, and risk management systems. In addition, we have established an internal control reporting system to ensure the reliability of financial reporting, and carry out effective and efficient operation and evaluation of this system. The Auditing Department conducts internal audits of the Group with respect to the maintenance and operation of these compliance systems and internal controls over financial reporting.

AMADA Group Corporate Code of Conduct

  1. Develop Customers’ Trust
  2. Interact with Local Communities
  3. Contribution to the International Community
  4. Compliance with Regulations
  5. Establishing a Relationship of Mutual Trust with Our Business Partners
  6. Sound Relationships with Government and Administrations
  7. Response to Antisocial Forces
  8. Promotion of Communication with Communities
  9. Creation of an Environment in which Employees can Achieve Personal Development and Satisfaction
  10. Contribution to Environmental Protection

Illustration：Diagram of the internal control system. Under the supervision of the Representative Director on the Board of Directors, there are the Export Control Division, the Safety and Health Committee, the Internal Control and Risk Management Committee, and the Environmental Eco Promotion Committee, and these committees and the Board of Directors are audited by the Board of Corporate Auditors and the Accounting Auditor. In addition, the Internal Audit Department conducts internal audits of business execution divisions and group companies and reports to the Board of Corporate Auditors, accounting auditors, and the Board of Directors.

Compliance

In addition to providing training to ensure thorough compliance, the AMADA Group has clarified procedures for responding to instances of compliance violations and disseminated these procedures to each of the Group companies. For the purpose of early detection and correction of legal violations and misconduct, we also operate an internal reporting system that allows anonymous reporting through the Auditing Department and/or outside contractors. As well, the Internal Reporting Treatment Rules have been revised to comply with the revised Whistleblower Protection Act, enacted in June 2022. These rules obligate us to maintain confidentiality with regard to whistleblowers and those who cooperate in investigations, and require that they not be subject to any disadvantageous treatment. To promote compliance education and awareness-raising activities, we continuously provide collective education, as well as online education programs that can be taken at any time.

Illustration：System diagram in response to the occurrence of compliance violations.

Anti-corruption

The AMADA Group has formulated the Basic Anti-Corruption Policy based on the AMADA Group Management Philosophy to “conduct sound corporate activities based on high ethics and fairness,” and all officers and employees* of the AMADA Group will comply with this policy.
For this policy, activities constituting corruption are those obtaining fraudulent gains through abuse of authority, including bribery, improper acceptance of kickbacks and rebates, embezzlement, money laundering, and obstruction of justice.

* “Employees” as defined in this policy includes regular employees, contract employees, temporary employees, part time workers, etc.

Basic anti-corruption policy

1. Compliance with regulations

All officers and employees of the AMADA Group will comply with anti-corruption laws and regulations applicable in all countries and regions where it conducts business activities.

2. Prohibition of providing bribes

All officers and employees of the AMADA Group will not, directly or indirectly, provide or offer any improper benefits or favors to any public official, etc., or to any private company or other business entity that does not fall under the category of a public official. Any request or suggestion of bribery, etc., received will be firmly rejected.

3. Prohibition of accepting bribes

All AMADA Group officers and employees will not accept or seek, directly or indirectly, any improper advantage or benefit from any person.

4. Implementation of training and awareness-raising activities

To raise awareness and understanding of anti-corruption practices among all officers and employees, the AMADA Group will make this policy and related regulations constantly available on the company portal, etc., and will strive to further disseminate the policy through periodic training and other measures. In addition, by disclosing this policy on our website, we will strive to ensure that all stakeholders understand the AMADA Group’s policy.

5. Operation of whistleblowing system and record retention

The AMADA Group protects the anonymity of whistleblowers and prohibits retaliatory treatment in the event of problems or suspicions regarding the prevention of corruption through a structure that allows for effective reporting through the whistleblower system. Upon receipt of a report, we will investigate and respond in good faith and take the necessary corrective actions. A series of records (including electronic records) concerning the receipt and investigation, etc., of whistleblower reports will be compiled and retained.

As described above, the AMADA Group will periodically verify whether this policy is functioning effectively and will review and improve it as needed.

Contact information for inquiries about AMADA’s products, product repair and recovery, and corporate activities.