Compliance and Corporate Ethics

Policy and Commitment

Code of Corporate Ethics and Conduct and Internal Corporate Structure

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. The Code sets out principles such as compliance with laws and regulations, fair bidding, the establishment of transparent relationships with political and administrative bodies, the eradication of antisocial conduct, and greater transparency in corporate accounting in order to prevent all forms of corruption, including coercion, bribery, money laundering, and obstruction of justice. It is also reviewed regularly in light of social conditions.

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).

Anti-Bribery Regulations

In addition to explicitly prohibiting bribery in our Code of Corporate Ethics, we have established a system to ensure strict compliance and have enacted these Anti-Bribery Regulations with the aim of preventing, before they occur, acts of bribery by officers and employees, as well as the provision of improper benefits to public officials and others.
Under these regulations, the Company prohibits officers and employees from engaging in bribery, both domestically and internationally, as well as from providing improper benefits to public officials or similar parties, whether directly or indirectly, or from ordering such actions in the course of their duties.
Furthermore, these regulations stipulate points of caution regarding business activities overseas. When using intermediaries or consultants overseas, we are required to confirm that there is no risk of such intermediaries engaging in bribery or providing improper benefits to public officials, and to enter into contracts with them that include clauses regarding legal compliance and the prevention of bribery.

To ensure that all officers and employees are fully aware of these regulations, the Company conducts ongoing and regular education and training programs. Furthermore, internal audits are conducted to verify that these regulations are being properly implemented.

In fiscal year 2024, there were no incidents involving bribery or the provision of improper benefits to public officials, etc., for which the Company faced legal action or was subject to fines or penalties.

Management System

Compliance Promotion System

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.

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). For reports received through the internal whistleblowing hotline, Shimizu investigates the facts and, based on the results of the investigation, takes corrective measures and other actions as necessary. We also ensure that users of the hotline are never subjected to any disadvantageous treatment and, in principle, inform them of the investigation results and other relevant matters.
Stakeholders outside of the Shimizu Group may consult with us via the contact information on our website.

Internal Whistleblowing System Diagram

Internal Whistleblowing System Diagram

Targets and Performance

Materiality Indicators and Results

FY2023 results FY2024 results
Progress of measures such as corporate ethics training based on The Analects and the Abacus
  • Corporate ethics training for senior management conducted
  • Compliance training provided to all employees, including e-learning
  • Corporate ethics training for senior management conducted
  • Compliance training provided to all employees, including e-learning
FY2022 results FY2023 results FY2024 results
Number of serious legal violations 0件 0件 0件

Donations to Political Funding Organizations

FY2024 results
Amount donated to political parties and political funding organizations 36 million yen

Initiatives

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

  1. Corporate ethics training for executive management (including management of Group companies)
  2. Compliance e-learning training (including Compliance with the Anti- monopoly Act)
    Every year, we provide e-learning on compliance for all employees. As part of this training, we cover the laws, regulations, codes of conduct, and other rules that employees must comply with, and we work to ensure that the necessary responses and related matters are thoroughly communicated and understood. After the training, we conduct a confirmation test to assess participants’ level of understanding. In addition, when there are important legal revisions or similar changes, we provide notice, as appropriate, via the intranet and other channels.

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.

Memberships and Collaborations

In March 2013, we signed and became a participant in the United Nations Global Compact and support Principle 10, “Anti-Corruption.”

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