Corporate Governance

Basic View

Based on our Credo, The Analects and the Abacus, we strive to fulfill social responsibilities through our business activities, thereby earning a greater degree of trust from our shareholders and investors, and all other stakeholders, including clients, employees, and local communities. We also aim to manage the company in an expeditious, efficient, transparent, and lawful manner to achieve sustainable growth and increase corporate value over the medium to long term.

To achieve this, we have established a structure that enables the Board of Directors and Audit & Supervisory Board Members to appropriately supervise and audit the performance of duties, based on separation of the management strategy decision-making function from the execution of duties function. Concurrently, our basic policy on corporate governance is for our directors, executive officers, audit & supervisory board members, and employees to practice compliance management based on high ethical standards.

Structure

Corporate Governance Structure of Shimizu Corporation

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Overview of the Corporate Governance Structure

We have adopted the structure of a company with an Audit & Supervisory Board. We have chosen this system based on the belief that we have established a system to supervise and oversee management from an objective and neutral perspective. This was achieved by limiting the number of directors and introducing an executive officer system to clearly separate the management strategy decision-making and oversight functions from the business execution function, by taking steps to encourage energetic debate at the Board of Directors, and by electing outside directors, other non-executive directors, and outside Audit & Supervisory Board members who maintain a high degree of independence. The concrete structure and implementation status are detailed below.

One-third or more of the Board of Directors elected are outside directors to strengthen management supervision function, and to promote more energetic debate by the Board of Directors.
Outside directors and other non-executive directors and outside Audit & Supervisory Board members use their extensive experience and sophisticated insight based on their individual career histories to oversee and supervise management and provide necessary advice as appropriate.
We established a structure mainly consisting of the head office administrative departments to provide timely information and other materials to assist outside directors and other non-executive directors in performing their management supervisory duties (including tours of offices, job sites, etc.).
The relevant divisions provide guidance on the Company in general, description of its businesses, and other relevant information to new outside directors and outside Audit & Supervisory Board members.
Audit & Supervisory Board members audit all duties performed by directors from a fair and impartial perspective.
The Audit & Supervisory Board Members Office was established as the dedicated organization to support Audit & Supervisory Board members. This office secures the necessary support staff to enable more effective audits by Audit & Supervisory Board members.
Audit & Supervisory Board members improve the effectiveness of management supervision by attending important meetings and obtaining sufficient information from officers and employees without delay.
When a Board of Directors meeting is held, the Board of Directors administrative office and other divisions provide explanations in advance to the outside directors, non-executive directors, and Audit & Supervisory Board members.
Outside directors and other non-executive directors regularly exchange opinions with the chairman and president. They also exchange opinions with outside Audit & Supervisory Board members.
Regular Outside Officers Meetings are held for outside directors and outside Audit & Supervisory Board members, and regular Outside Directors and Audit & Supervisory Board Members Meetings are held for outside directors and all Audit & Supervisory Board members to facilitate the exchange of opinions.

Main Governing Bodies Established by Shimizu (including discretionary committees and other meeting formats)

Board of Directors

The Board of Directors holds meetings once a month as a rule, and as needed. It makes decisions on matters specified in laws and regulations and the Articles of Incorporation as well as other important matters, and supervises the execution of duties. The Articles of Incorporation specifies 12 as the maximum number of directors. These directors consist of executive directors who are highly knowledgeable in each area of our business and non-executive directors, some of whom are outside directors with extensive expertise and experience in their respective specialties. The Chairman and Representative Director serves as the chair of the Board of Directors.

［Names and Titles of Members］　(11 as of June 27, 2025)

Chair	Kazuyuki Inoue　(Chairman of the Board and Representative Director)
Members	Internal Directors	Executive	Tatsuya Shimmura, Kentaro Ikeda, Takeshi Sekiguchi, Yoshito Tsutsumi, Yoshiki Higashi
	Internal Directors	Non-executive	Noriaki Shimizu
	Outside Directors	Tamotsu Iwamoto, Junichi Kawada, Mayumi Tamura, Yumiko Jozuka

(Main Agenda Items)
Election of directors; organizational reform; establishment, revision or repeal of company regulations; formulation and supervision of management policies and strategies; monitoring of progress and growth strategies of each business; risk management; sustainability matters such as climate change and human resources development; feedback on dialogue with investors; reduction of securities holdings; and revision of the standards for referral to the Board of Directors.

Audit & Supervisory Board

The Audit & Supervisory Board meets once a month as a rule, and additionally as necessary. It makes decisions on audit policy, audit plans, auditing methods, and other important audit matters, and deliberates on necessary matters concerning audits. The Articles of Incorporation sets the number of Audit & Supervisory Board members at a maximum of five, including three outside Audit & Supervisory Board members. The chair of the Audit & Supervisory Board is an Audit & Supervisory Board member chosen through discussion by the Audit & Supervisory Board.

［Names and Titles of Members］　(five as of June 27, 2025)

Chair	Hiroshi Kobayashi (standing)
Members	Audit & Supervisory Board Member (standing)	Tomohiko Hirayama
Members	Audit & Supervisory Board Member (part-time)	Kaoru Ishikawa, Toshie Ikenaga, Ko Shikata (all outside Audit & Supervisory Board members)

Nomination & Compensation Committee

We have established a Nomination & Compensation Committee to ensure fairness and transparency in the selection and dismissal of directors, Audit & Supervisory Board members and executive officers, as well as evaluation and compensation of directors and executive officers. The members of this committee consist of five non-executive directors (four outside directors and one non-executive internal director) and one executive director. The committee is chaired by a non-executive director elected every year from among the members.

［Names and Titles of Members］　(six as of June 27, 2025)

Chair	Noriaki Shimizu (non-executive internal director)
Members	Outside Directors	Tamotsu Iwamoto, Junichi Kawada, Mayumi Tamura, Yumiko Jozuka
Members	Internal Director	Tatsuya Shimmura (President and Representative Director)

(Main Agenda Items)
Creation of personnel appointments for and individual evaluations of directors and executive officers, total amount and individual bonuses for officers, individual monthly compensation for the next fiscal year, succession plans, and review of related regulations.

Risk Management Committee

Our Risk Management Committee ascertains and analyzes risks that would have a serious impact on our corporate group, which consists of Shimizu and its subsidiaries. It also determines key items of risk management, and follows up and reports to the Board of Directors. The President and Representative Director serves as the chair of the committee and one standing Audit & Supervisory Board member also attends committee meetings.

［Names and Titles of Members］　(15 as of June 27, 2025)

Chair	Tatsuya Shimmura (President and Representative Director)
Members	Kentaro Ikeda, Takeshi Sekiguchi, Yoshito Tsutsumi, Masanobu Onishi, Takao Haneda, Yoshiki Higashi, Hideo Yokoyama, Tomoaki Harada, Michiho Yamaguchi, Nobuyoshi Kikuchi, Taizo Tsukada, Deputy Manager of DX Management Office, General Manager of Audit Dept., Tomohiko Hirayama (standing Audit & Supervisory Board Member)

Committee on Corporate Ethics

We have established the Committee on Corporate Ethics to determine company-wide policies on strict compliance with corporate ethics, laws and regulations, and deploy and follow up on compliance. The committee is also tasked with collecting all information on serious incidents involving wrongdoing as well examining ways to prevent incidents and recurrence and issuing directions to accomplish that. The President and Representative Director serves as the chair of the committee. One full-time Audit & Supervisory Board member and one outside expert (an attorney) also attend committee meetings.

［Names and Titles of Members］　(19 as of June 27, 2025)

Chair	Tatsuya Shimmura (President and Representative Director)
Members	Kentaro Ikeda, Takeshi Sekiguchi, Yoshito Tsutsumi, Masanobu Onishi, Takao Haneda, Yoshiki Higashi, Hideo Yokoyama, Hitoshi Fujita, Michiho Yamaguchi, Nobuyoshi Kikuchi, General Manager of Legal Affairs Dept., General Manager of Human Resources Dept., General Manager of General Affairs Dept. and Manager of Corporate Ethics Help-Line Office, Manager of Group Companies Strategy Office, General Manager of Audit Dept., Senior General Manager of Business Development & Marketing Headquarters, Hiroshi Kobayashi (standing Audit & Supervisory Board Member), outside experts (attorneys)

Executive Officers Council

We have established an Executive Officers Council to communicate important matters and policies decided by the Board of Directors to executive officers and provide instructions to them. The President and Representative Director serves as the chair of this council and members consist of executive directors (other than the chair) and executive officers. Two full-time Audit & Supervisory Board members also attend council meetings.

Evaluating the Effectiveness of the Board of Directors

Our Board of Directors evaluates the overall effectiveness of the Board of Directors once a year.
A summary of the evaluation method and results for fiscal 2024 are provided below:

Evaluation Method

All directors and Audit & Supervisory Board members complete a survey (including anonymous entries and open answers). A self-analysis is performed through discussion by all directors and all Audit & Supervisory Board members at Board of Directors meetings, based on an analysis by a third party (attorney).

Period covered	April 2024 to March 2025
Dates performed	Board of Directors meetings on March 7, March 26, and April 25, 2025
Main items evaluated	Board of Directors composition/operations, management strategy/management supervision function, corporate ethics/risk management, response to sustainability issues, process of determining nomination/compensation, human resources development, communication between outside directors and management, dialogue with shareholders/investors, etc.

Summary of Evaluation Results

Conclusion: The Shimizu Board of Directors evaluated and determined the Board of Directors as a whole to be operating effectively.

Status of response to issues indicated in the last evaluation of effectiveness in FY2023 (covering April 2023 to March 2024)

The Board of Directors has made consistent efforts to resolve issues and make improvements as follows. The Board of Directors will continue to strive for further improvement.

Monitoring and supervision of the progress of the Mid-Term Business Plan by the Board of Directors

・

Strengthen monitoring of how the Mid-Term Business Plan and the annual Operation Plan are linked, how it is adopted across the Company and its progress

→

Holding explanatory meetings/group meetings for better understanding and achievement of the Mid-Term Business Plan. Opinions of the participants shared at the Board of Directors. Implement follow-up measures to ensure better understanding of the Mid-Term Business Plan and better incorporation into the annual Operation Plan.
The Board of Directors to check that management resources are appropriately distributed

・

Further discussions on business portfolio taking into account medium to long-term growth

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Gather all Directors at offsite meetings, and hold discussions on precedents of business 　portfolio optimization. Have in-depth discussions on growth strategies for each line of business at the Board of Directors.
Sharing the deliberation status, etc. of the Nomination and Compensation Committee at the Board of Directors

・

The Board of Directors to check the deliberation process of the Nomination and Compensation Committee in addition to its result

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The deliberation process and discussion details of the Nomination and Compensation Committee, outline of succession planning and other implementation matters to be shared at the Board of Directors.
Expanded disclosure of non-financial information

・

Expanded information disclosure related to risk management and sustainability

→

Review risk management process and items, continue discussions on disclosure details for better disclosure. Early information disclosure based on the TCFD and TNFD recommendations.

Major issues identified in the effectiveness evaluation.

Hold in-depth discussions on business portfolio optimization to enhance corporate value

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Hold more in-depth discussions on growth strategies for each line of business considering the cost of capital at the Board of Directors, clearly define roles of each line of business in a company-wide scheme to enhance corporate value
Further improve internal control and risk management systems in order to realize teachings of our Credo, the Analects and the Abacus, in our operation

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Establishing a reporting system where details of risky projects are more promptly reported. Creating a more systematic reporting system where the progress and completion of the responses can be shared.
Enhance the communication between our senior management and Outside Directors/Outside Auditors

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Provide more opportunities for our senior management and Outside Directors/Outside Auditors to talk to each other in person outside the Board of Directors meeting.

Future initiatives

Based on the results of the evaluation of the effectiveness of the Board of Directors, we aim to enhance the effectiveness of the Board of Directors and further expand and reinforce corporate governance through the PDCA cycle to improve on issues.

Election of Outside Directors and Outside Audit & Supervisory Board Members

as of June 27, 2025

Criteria for Assessing Independence of Outside Directors and Outside Audit & Supervisory Board Members

Criteria for Assessing Independence of Outside Directors and Outside Audit & Supervisory Board Members(PDF：91KB)

Support Structure for Outside Directors and Outside Audit & Supervisory Board Members

We have established a system to provide information to facilitate supervision of management by outside directors and other non-executive directors in performing their duties. The administration departments in the head office play the main role in providing this information in a timely manner. The Corporate Auditor’s Office was established as a dedicated organization to support Audit & Supervisory Board members. A sufficient number of staff members have been secured to assist outside Audit & Supervisory Board members. When a Board of Directors meeting is held, materials are distributed in advance and the Board of Directors administrative office and other divisions provide explanations in advance to the outside directors and the outside Audit & Supervisory Board members.

Directors, Audit & Supervisory Board Members, and Executive Officers

Management Team

Officer Compensation

Policy on Determining Officer Compensation

The remuneration of each Director of the Company, which consists of a fixed-amount monthly salary that is the base salary and performance-based compensation that comprises bonuses and compensation exclusively for purchasing shares of the Company, is decided through deliberations of the Nomination and Compensation Committee, which is made up of a majority of Outside Directors and is chaired by a Non-executive Director, and which was established to evaluate the performance of Directors and decide on their remuneration in a fair and transparent manner, based on a resolution passed at the Board of Directors.
Non-Executive Directors including Outside Directors and Audit & Supervisory Board Members are paid only fixed-amount monthly salary for the purpose of enhancing their supervisory function of management.

We, at a Board of Directors’ Meeting held on February 24, 2021, resolved regulations for executives' remuneration that set forth the policy for determining the remuneration of each Director. Its outline is provided below.

Policy on Base Salary

Of the remuneration, etc. of Directors of the Company, the fixed-amount monthly salary that is the base salary is a maximum total of 90 million yen a month (including a maximum of 10 million yen for Outside Directors) pursuant to a resolution passed at the 117th Annual General Meeting of Shareholders held on June 27, 2019. As of the closing of the 117th Annual General Meeting of Shareholders, the number of Directors was 12 (including 3 Outside Directors).
Remuneration for Audit & Supervisory Board Members is a maximum total of 13 million yen a month pursuant to a resolution passed at the 89th Annual General Meeting of Shareholders held on June 27, 1991 and is decided through discussions at Audit & Supervisory Board. As of the closing of the 89th Annual General Meeting of Shareholders, the number of Audit & Supervisory Board Members was 4.

Policy on Performance-based Compensation

Of the remuneration, etc. of Directors of the Company, bonuses that are performance-based compensation is a maximum total of 500 million yen a year based on a resolution at the 118th Annual General Meeting of Shareholders held on June 26, 2020, and the Nomination and Compensation Committee deliberates on whether or not a bonus shall be paid and on what amount shall be paid.
The bonus amount is calculated according to the following method based on consolidated net income, the final results of the Group’s business activities for a business year. The “performance coefficient” used to calculate the bonus amount has been updated at the Board of Directors’ Meeting held on January 31, 2025 considering a proposal for deliberation presented by the Nomination and Compensation Committee to make it more clearly defined and provide management more incentives. The new coefficient is applied from the fiscal year starting on April 1, 2025.

(Method of calculating individual performance-based compensation ［bonuses］)
Consolidated performance*1 x Performance coefficient*2 x Positional index*3 x Individual evaluation coefficient*4 = Individual bonus*5

　　　*1. Consolidated net income for the current fiscal year (Net income attributable to shareholders of the Company)
*2. The Nomination and Compensation Committee determines the earnings coefficient using ordinary income which represents the result of basic business development of the Company and an achievement rate against the targets set for the fiscal year of awards profitability of the construction business, a leading indicator of the business results for coming fiscal years, as main evaluation items. Other items are selected from non-financial KPIs from the Mid-Term Business Plan and added by the Nomination and Compensation Committee based on priority in terms of enhancing mid-to-long term corporate value and objectivity of evaluation. The Nomination and Compensation Committee then considers whether or not there is any material violation of laws and decides the earnings coefficient based on the evaluation value derived by weighted average of each item.
*3. An index determined for each Director’s position
*4. The Nomination and Compensation Committee determines individual evaluation indices based on the results of evaluations of the level of achievement of targets set for each director based on interviews with Executive Directors at the beginning and end of the fiscal year. (Evaluation indices range from 65% to 135%)
The multifaceted evaluations cover the short-term performance of each director in addition to their level of contribution to achieving the targets of the Mid-Term Business Plan, their efforts to strengthen the management base, their contributions to sustainability, and their performance as directorships.
Notably, only the non-executive directors of the Nomination and Compensation Committee Members make decisions regarding executive director evaluations.
*5. To encourage the further sharing of values with shareholders and increase corporate value over the medium to long term, an amount corresponding to 20% of the bonus as performance-based compensation, shall be deemed to be compensation for purchasing the Company’s shares, and each Director shall contribute this remuneration to the Executives’ Shareholding Association, which shall acquire the Company’s shares. The Company’s shares that are acquired in this way shall continue to be held for the duration of the Director’s tenure and for a fixed period of time after resignation.

Matters concerning delegation of decisions on compensation, etc.

We have established a Nomination & Compensation Committee which consists of a majority of outside directors and is chaired by a non-executive director, to ensure fair and transparent evaluation and compensation of directors and officers through deliberation by the committee based on the resolution of the Board of Directors.
The Nomination & Compensation Committee reviewed compensation for last fiscal year ended March 31, 2025 and discussed the base monthly salary and the amount to be paid as bonuses for each director according to the evaluation of the performance of each director, based on the Rules on Officer Compensation. The committee determined the compensation to be in line with policy determined by the Board of Directors.

Director and Audit & Supervisory Board Member Compensation

FY2024

Securities Holdings

Policy on Securities Holdings

When there is a necessity from the viewpoint of business development, we acquire and retain shares of clients and business partners to strengthen and maintain relationships. Acquisition of major securities is determined by the Board of Directors, taking comprehensive consideration of benefits to the Company, acquisition cost, risk of share price changes and other factors. The Board of Directors examines the necessity of securities holdings for individual stocks each year, taking into consideration its economic rationality, including cost and risk of holding them, and business development benefits. Based on such examination, shares that have become dilutive in terms of significance to our operations, are disposed while confirming relationships with business partners.

Status of Reduction of Securities Holdings

To effectively use our capital, we established a following goal: “to reduce the ratio of the outstanding amount of securities holdings to consolidated net assets to less than 20% by the end of March 2027”, and announced it to the public on April 26, 2023. Since then, we have been seeking to reduce the volume of securities holdings. At the Board of Directors Meeting held on November 12, 2024, we have decided to move up the target date of the existing reduction goal by one year to the end of March 2026, so that we can accelerate the implementation of “management that is conscious of cost of capital and stock price”. We have also established a new goal of reducing the ratio of the outstanding amount of securities holdings to consolidated net assets to less than 10% by the end of March 2027”.
We sold shares of 31 listed companies during fiscal 2024 (including shares of which part of the holdings were sold). The proceeds were ¥58.6 billion. From fiscal 2018 to fiscal 2024, the total number of listed companies of which we sold its holdings was 91 (including shares of which part of the holdings were sold). The proceeds were ¥208.6 billion.
As a result, the number of listed companies we held shares in decreased from 187 as of the end of March 2018 to 123 as of the end of March 2025.
As of the end of March 2025, the proportion of securities holdings in consolidated net assets is 27.0%.

Criteria for exercising voting rights pertaining to securities holdings

We exercise voting rights on securities holdings after comprehensively examining the contents of proposals, referring to the Policy on securities holdings above, and judging whether to vote for or against each proposal from the perspective of whether the corporate value of the Company and business partners may increase.

Policy in case the cross-shareholder has expressed their intention to sell the shares

In case the cross-shareholder has expressed their intention to sell the Company’s shares, we will not act to prevent the sale by, for example, suggesting that we will reduce transactions with the company concerned.

Internal Control System Establishment

We have established a Basic Policy on Establishing a System of Internal Controls based on the Companies Act.

Basic Policy on Establishing a System of Internal Controls (Only in Japanese) (PDF： 223 KB)
Last revision： March 9, 2021

Internal Control System Status

We have established a system of internal controls and the Board of Directors makes decisions on the Basic Policy on Establishing a System of Internal Controls to ensure proper operation of the company.
An overview of the operational status of internal control systems in fiscal 2024 is provided below.

Compliance System	We provide ongoing education and training to officers and employees to ensure strict compliance. We have established three whistleblowing hotlines, the Corporate Ethics Help-Line Office, the Harassment Contact Point, and the External Contact Point, based on the internal whistleblowing system and familiarized employees with them. The operating status is reported to the Corporate Ethics Committee, the Risk Management Committee, the Audit & Supervisory Board, and the Board of Directors. The Corporate Ethics Committee meets twice a year. It rolls out measures aimed at strict compliance with corporate ethics and laws and regulations to the entire company and follows up on implementation.
Risk Management System	The Risk Management Committee meets twice a year. It identifies and analyzes risks that would have a serious impact on the corporate group, which consists of Shimizu and its subsidiaries, and determines the key items of risk management. It follows up on implementation and reports to the Board of Directors. To confirm communication lines and the initial response to large earthquakes, we hold regular earthquake disaster drills (twice a year) and ask business partners and local residents and others to participate. For overseas safety risks, we collect information on hazards based on the Outline of Countermeasures for Overseas Emergency. As necessary, we also strengthen the security structure, issue warnings to relevant people, and limit overseas travel. To firmly establish information security measures and make sure that everyone understands them, we provide ongoing education and training to officers and employees, share information with relevant divisions, and respond swiftly when a problem occurs.
Systems to Ensure Proper Operation of the Shimizu Group	Shimizu holds two meetings a year to share information between the President of Shimizu and the presidents of group subsidiaries. We manage important items related to operational execution at subsidiaries through the Subsidiary Management Regulations. The Audit Department performs internal audits of subsidiaries based on the audit plan. Proper operational execution by subsidiaries is also monitored by dispatching auditors and other means.
System for Ensuring Effectiveness of Audits by Auditors	The Audit & Supervisory Board Members Office is an organization dedicated to assisting the Audit & Supervisory Board. It is staffed with three full-time employees. An Audit & Supervisory Board member designated by the Audit & Supervisory Board attends important meetings such as the Chief Executives' Meeting, the Division Directors' Meeting, Risk Management Committee meetings, and Corporate Ethics Committee meetings.

Risk Management

Compliance

Code of Corporate Ethics and Conduct and Internal Corporate Structure

Code of Corporate Ethics and Conduct

We have adopted The Analects and the Abacus, which contains the teachings of Eiichi Shibusawa, as our corporate credo. We base our business activities on the conviction that our company’s business will always prosper if we pursue ethics and economic gain simultaneously, or in other words, if we do good work that delights the community and our customers and is grounded in a strong sense of ethics. In this era of strong demand for corporate social responsibility, we have established the Code of Corporate Ethics and Conduct to ensure that all officers and employees thoroughly understand The Analects and the Abacus and demonstrate it in their daily actions. We are committed to enforcing corporate ethics, including compliance with laws and regulations.

Establishment of Internal Corporate Structure

We provide education and training to ensure strict implementation and practical operation of the Code of Corporate Ethics and Conduct by officers and employees. We have also appointed an officer in charge of corporate ethics, established a Committee on Corporate Ethics, the Corporate Ethics Office, the Corporate Ethics Help-Line Office, and an internal whistleblowing system.

Proper Management of Personal Information

In addition to establishing the Privacy Policy, we have appointed a Corporate Personal Information Protection Administrator to promote appropriate measures for the proper management of personal information, including individual numbers (the “My Number” system).

Internal Whistleblowing System

The Shimizu Group has established an internal whistleblowing system allowing officers and employees of Shimizu, subsidiaries, and subcontractors to consult about or report various compliance issues that may arise within the Group, anonymously or otherwise. This encompasses actions by officers and employees of the Group that may violate the Code of Corporate Ethics and Conduct (such as harassment and other human rights violations, accounting fraud, bribery, and other corrupt practices).
Under this system, a Corporate Ethics Help-line Office, a Harassment Consultation Desk, and an External Consultation Desk staffed by outside attorneys have been established as Consultation and Reporting Desks (Compliance Hotlines). Reports submitted to these desks are thoroughly investigated, and appropriate measures are taken as needed. We ensure that whistleblowers are not subjected to any adverse treatment.
Stakeholders outside of the Shimizu Group may consult with us via the contact information on our website.

Internal Whistleblowing System Diagram

Initiatives Aimed at Strengthening Compliance

We implement various measures that will help cultivate an ethical mindset and contribute to strict compliance among Group officers and employees, so that they put the spirit of our corporate credo, The Analects and the Abacus, into practice in their actions.

Top management will lead by example in cultivating an ethical mindset and strict compliance.

Corporate ethics training for executive management (including management of Group companies)
Compliance e-learning training (including Compliance with the Anti- monopoly Act)

Make sure that everyone understands the code of conduct on bidding for construction projects (mainly for Shimizu and construction-related subsidiaries)

We conduct training and interviews for officers and employees to ensure thorough awareness of the code of conduct as well as interviews by outside attorneys and other experts as necessary on a case-by-case basis.

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