Compliance

At the GMO Internet Group, we take care to follow all regulations and gain society's trust by maintaining high moral standards and by enforcing a compliance system that helps develop our business activities as our aim is to build a trust-based relationship with our stakeholders. The company has enacted the "GMO Internet Group Compliance Declaration," which defines our group, for realizing the above aims.

GMO Internet Group Compliance Declaration

GMO Internet Group believes that all of its executives and employees (we call "partners" hereafter) should act with integrity in accordance with laws and, regulations, and adhere to social norms based on the "Venture Spirit Declaration" our corporate philosophy, which outlines our consistent goals and values, and which allows us to earn the trust of stakeholders. This Compliance Declaration provides guidelines to ensure that we, as partners, act correctly and appropriately, maintain trust in our company, and continue to a corporate group that will last for 100 years. We put this guidance into practice, protect our services, customers, and partners, create "smiles" and "excitement" for everyone involved, and strive to be a group that continues to grow.

Basic Philosophy

  1. We recognize that each of us represents the company. We act with high ethical standards and aim to earn the trust of all stakeholders.
  2. We will abide by GMO Internet Group's Venture Spirit Declaration and this Compliance Declaration, and we will not pursue profits in violation of either.
  3. We will comply with all applicable laws, regulations, and company rules and standards of conduct. Our actions will demonstrate a transparent and honest approach that is not detrimental to our customers, society, or to our own families.
  4. We respect human rights, which are the birthright of all people, recognize diverse values, and create a working environment where every partner's motivations and abilities can be fully demonstrated.
  5. When we find any acts or suspicious activity, contrary to or in breach of laws, regulations, social norms, or our Compliance Declaration, or when we face a situation that requires us to act in a manner that is contrary to them, we will not turn a blind eye but will consult with our superiors or the appropriate departments. If we are unable to consult with our superiors or the appropriate department, we will report through the internal reporting system (GMO helpline).

Framework

The Group shares the mindset it has cultivated in the form of the "Spirit Venture Declaration," and sets it as the foundation of its corporate activities. In addition, we have established a set of guidelines for ethical and compliance-based actions required of our partners, named the "Compliance Declaration," and have established a compliance structure. The Management Council oversees the penetration and effectiveness of the "Spirit Venture Declaration" and the "Compliance Declaration," and periodically revises and approves them.

  • At the meetings of the Board of Directors and the Management Council, where management decisions are made and execution of duties is reported, legality is confirmed by seeking the opinions of the Audit and Supervisory Committee Members with respect to all agendas.
  • The Company also holds "Compliance Workshops," establishes the "GMO Helpline" to operate a consultation and whistleblowing framework, and works to ensure the effectiveness of prevention, early detection, and self-correction of fraudulent acts, etc. in an effort to enhance compliance management.
  • The "Group Financial Business Cooperation & Group Internal Audit Office" conducts audits to determine whether the execution of business is in compliance with laws, regulations, the Articles of Incorporation, etc.
  • Furthermore, the Company has established the "Risk Management Committee." A meeting of the Committee is convened in principle on a monthly basis, to discover at an early stage compliance risk information that may cause damage to the Group and respond to risks that become evident.
  • In addition, the Company also holds quarterly "Group Compliance Meetings" that the legal officers at the Group's public listed companies participate in and regularly shares the situation of a compliance system of other companies in the Group to achieve the enhancement of the compliance throughout the Group. Furthermore, the Group's information is reported immediately to Group Legal Department as soon as compliance violations occur, and we have established a system that responds appropriately and quickly.

Internal reporting system

We have established internal reporting channels for our partners and external reporting channels for other individuals, with the external reporting channels being available to anyone outside of the company, including former employees. Reports are independently investigated by the relevant department, which then provides feedback to the whistleblower regarding the investigation and response outcomes. In addition, when illegal acts are found, they are promptly corrected, and the offender is punished and the reporter is rewarded in accordance with the employment regulations.

  • GMO Helpline/Nadeshiko Helpline

    In order to discover, ameliorate, or prevent all compliance risks, including overall bribery and corruption prevention in business activities, and human rights infringements at an early stage, we have a system that enables partners to consult with the company or solve problems, without undue worry, if they become aware of fraudulent acts or illegal acts in work, or if they see or hear acts that may be illegal though it's uncertain whether the acts are clearly illegal. We also have female consultants in case the female partners are unlikely to consult with male consultants (available for use by male partners as well). Whistleblowing can also be anonymous.
    Personal information, comments, or details of the consultation of individuals who consult with us will be managed under strict guard and we will never leak them to third parties without their acceptance. In addition, we prohibit retaliation against partners who report violations of laws and regulations to the Company because they have reported such violations, and we respond in good faith to ensure that those who have suffered human rights violations receive redress.

  • External helpline to report problems

    If the actions of our directors, partners, etc. are a possible violation of laws and regulations, we have an external helpline to report (or facilitate consultation on) those problems. This helpline is available for use by anyone outside the company, which includes customers and retired workers. Whistleblowing can also be anonymous.
    https://www.gmo.jp/contact/compliance/[Japanese version only]

Education and training program

The Board and partners should comply with laws and regulations, be ethical, and be capable of taking actions based on our corporate philosophy of the Venture Spirit Declaration. The Group believes this will further enhance the stakeholders' confidence in the organization and has established the "Compliance Declaration," which is a guidelines for action based on social ethics and compliance required of our group's partners.In order to promote and implement this Declaration, we provide training programs on the "Compliance Declaration" every year for all of our partners.
We provide training programs on the introductory guide to compliance for new graduates and mid-career partners when they join the Company. We also provide training programs on compliance, including bribery and corruption prevention, at least once a year for all partners, and specific theme ranges from insider trading or harassment prevention to personal information protection and information security. GMO Internet Group is working hard to enhance compliance consciousness and reinforce knowledge.

Corruption prevention initiatives

As a corporate group that conducts business activities not only in Japan but also overseas, including Southeast Asia, the Group recognizes the risk of bribery and has established the Group-wide ""Anti-Bribery Guidelines"" to prevent and detect bribery at an early stage. Furthermore, we recognize that the prevention of bribery and corruption is an important issue, and the Board of Directors oversees our policies and guidelines.
In addition, we regularly assess the risk of corruption in each business and provide the necessary training in high-risk businesses. If we receive a request that could be considered an improper benefit, such as the payment of money or the provision of goods to a bribe target as defined in each country, we encourage employees to contact the Legal Department or use the Group's common internal reporting system (GMO Help Line) and require employees to report any entertainment or gifts from business partners on a common form.
In our relationships with business partners, we use external databases and other means to search for attribute information as necessary, and our contracts contain clauses on anti-bribery and anti-corruption, and on the exclusion of antisocial forces.
With regard to involvement in politics and policy, we recognize the social responsibility of our group as a provider of Internet infrastructure services, and we intend to engage appropriately in policies related to areas closely related to our business in order to contribute to the public interest, based on the social significance of such policies.

The status of compliance violations

There were no applicable cases from FY2019 to FY2022.

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