Compliance | Okamura Foods

Basic Policy and Initiatives

Basic Policy

We aim to continue to develop as a trusted corporate group by ensuring that each and every group employee complies with laws and regulations and engages faithfully in their daily work with a high level of ethics.

We position compliance with corporate ethics and laws and regulations as one the top priority tasks of management. To fulfill our mission of “To supply healthy seafood to the people of the world in a responsible way with respect for nature,” first we must be a corporate group trusted by society. The company has established the following systems and continues working to steadily instill these systems within the group.

Compliance Promotion System

(1) Risk and Compliance Committee

The Risk and Compliance Committee (chair: Chief Executive Officer) consists of members including internal directors, outside directors who are Audit & Supervisory Board members, executive officers, department heads, and the General Manager of the Internal Audit Department. The committee reports on compliance and risk management comprehensively for the entire company with regard to our operations and reviews countermeasures. Department heads manage risk in the daily business activities of their respective department, as well as report on problems identified in daily business activities and their response, and escalate other issues, to the Risk and Compliance Committee.

Additionally, a system is in place to obtain advice from outside experts, as the need arises, such as legal counsel, certified public accountants, tax accountants or labor and social security attorneys, in an effort to prevent risk or discover them at an early stage.

(2) Development and Informing of Compliance Rules

The company has established the Risk and Compliance Regulations, in addition to other compliance-related regulations. Mandatory compliance training is held annually for all officers and employees.

Whistleblower System

Approach

As compliance initiatives that form part of corporate management become even more important, we recognize that its whistleblower system plays an extremely important role in our promotion of compliance.

With this in mind, the company established the whistleblower system covering the entire Group in 2021.

Expected Effects

(1) Function for early detection of scandals

Recognizing the signs and beginnings of problems and making appropriate corrections at an early stage will function to prevent incidents from developing into major problems. This function is expected to be the most effective control, especially against fraud involving concealment.

(2) Function for prevention of scandals

The effective functioning of the whistleblower system is expected to serve as a deterrent to legal violations.

(3) Function for fostering trust among shareholders, business partners, and other stakeholders

The occurrence of scandals can greatly damage the credibility of the company and cause damage to shareholders, business partners, and other stakeholders. The effective functioning of the whistleblower system will mitigate these risks and ultimately contribute to building trust with stakeholders.

Overview of System

We have established one internal contact point and two external contact points as whistleblower hotlines.

The General Manager of the Administration Division and the General Manager of the General Affairs and Human Resources Department serve as the internal contact point. Once a report is received, the person in charge will confirm the facts and take necessary action. The results will be reported to the Risk and Compliance Committee.

The company’s legal counsel serves as the external contact point. One location is for domestic whistleblower reports that may be difficult to submit to the internal contact point, such as management misconduct. In addition, one of the external contact points accepts reports in English so that it is accessible to all officers and employees of overseas subsidiaries. When a report is submitted to an external contact point, the person in charge will inform either the internal person in charge of whistleblower reports or the Audit & Supervisory Board depending on the nature of the report. The person in charge of whistleblower reports or the Audit & Supervisory Board will confirm the facts of the report and take necessary actions.

Reports can be submitted by email, telephone, in person, or in writing. Suggestion boxes have been installed at our Aomori plant entrances to accept reports with a higher degree of anonymity.

Workflow of whistleblower reports

We formulated the Whistleblower Regulations to ensure that whistleblowers will not be treated unfairly as a result of submitting a report. These regulations also establish an appropriate handling system to detect and correct misconduct at an early stage to strengthen compliance management.

In addition, status updates are regularly reported to the Risk and Compliance Committee to check the operational status of the whistleblower system. At the same time, the committee is intended to serve as a venue to reaffirm risk perceptions among attendees (mainly department managers).

In FY2025, there was three whistleblower report, but none involved a serious incident.

Response to Anti-social Forces

We are working to block and/or sever all relationships with anti-social forces by establishing the Basic Policy on Elimination of Relationships with Anti-social Forces and creating detailed countermeasures as laid out in the Regulations on Elimination of Anti-social Forces and Response Manual for Dealing with Anti-social Forces.

Basic Policy on Elimination of Relationships
with Anti-social Forces

1. The company shall block and/or sever any and all relationships with anti-social forces such as organized crime groups, members of organized crime groups, quasi-members, companies affiliated with organized crime groups, corporate racketeers, groups engaging in criminal activities under the pretext of conducting social campaigns or political activities and crime groups specialized in intellectual crimes (hereinafter, referred to as "anti-social forces").
2. The company will develop the following system for the elimination of anti-social forces.
1. (1) Establishment of department to address anti-social forces
2. (2) Formulation of regulations and manuals for elimination of anti-social forces
3. (3) Establishment of collaborative system with external specialist organizations
4. (4) Documentation in company regulations
5. (5) Introduction of clauses on elimination of organized crime
6. (6) Establishment of other systems required for the elimination of anti-social forces
End

February 26, 2021
OKAMURA FOODS CO., LTD.