Compliance

Basic Views on Compliance

Basic Views on Compliance

The Samty Group is working to become a free and new company that can contribute to society while providing a rich urban environment. Compliance is the foundation of such corporate activities, and we consider compliance with laws, regulations, and formalities to be the norm, and aim to gain the trust of our customers and partners and prevent accidents and problems by reliably and accurately performing each of our daily tasks. It has been proven through many cases of misconduct in the past that simply complying with laws and regulations is not enough to meet the demands of society, including situations in which laws and regulations are not consistent with actual conditions. We regard the true compliance of the Group as going beyond mere compliance with laws and regulations to adapt to the demands of society.

DFF Inc.

Code of Conduct and Values

Code of Conduct and Values

The Group has stipulated its Management Philosophy and Code of Conduct, “Samty 5,” as a common standard for all employees and officers to comply with laws and regulations, the Articles of Incorporation, and social norms as a matter of course, and to engage in sincere and appropriate corporate activities with high ethical standards and carries out daily operations under a common set of values that aim to realize dreams.

Code of Conduct for Employees of the Samty Group, “Samty 5”

1. “Thank you” rather than “I’m sorry.”

When someone helps you, say “thank you” instead of “I’m sorry.” Positive words brighten both you and the other person.

2. Don’t forget your initial enthusiasm and sense of ethics.

Remember where you aimed to be on your first day of work. What should you do to get there? What should you not do? Let’s work today, remembering the fresh feeling you had on that day and sense of ethics.

3. Let’s be brave and raise your hands.

Everyone can think, “This would be a good idea,” or “What about this idea?” But only a few people can raise their hands. A little courage can lead to great growth.

4. It’s fun to know what you don’t know!

The view outside the train. What kind of buildings are there? What kind of people live there? How did the streets come to look the way they do? Such interest naturally broadens our perspective. It makes work and life more interesting.

5. Let’s question the rules.

Success lies beyond the norms. Can’t we do better than what we are now doing? Can’t we grasp something greater by abandoning what we have? There are plenty of opportunities to change the industry.

Values of the Samty Group

Figure
DFF Inc.

Compliance Promotion System

Compliance Promotion System

With the aim of ensuring the effectiveness of compliance management, the Group has appointed Hiroaki Matsui, Managing Director of Samty Co., Ltd., as the Chief Compliance Officer, and the Company’s Legal Department serves as the Compliance Control Division. This Division formulates an action plan as an implementation plan for compliance management, conducts training sessions, inspects the status of legal compliance, and performs daily monitoring and other activities to ensure that the Management Philosophy, Code of Conduct, Compliance Regulations, and Compliance Manual are thoroughly understood and practically implemented. In addition, to ensure cross-sectional management of the overall internal control system, the Legal Department is working to strengthen the internal control system through company-wide and group-wide efforts.

Compliance System of the Samty Group

Role of the Compliance Control Division

  1. Establishment, maintenance, and management of internal legal compliance systems
  2. Guidance and support for the establishment, maintenance, and management of legal compliance systems at Group companies
  3. Development and maintenance of legal compliance manuals
  4. Training and education on legal compliance
  5. Monitoring of legal compliance status
  6. Investigation and response when problems occur
organization chart
  • *Overseas subsidiaries operate a separate reporting and consultation counter (external contact).
DFF Inc.

Compliance Training

Compliance Training

To ensure that all employees share a common awareness of compliance, we have established Compliance Regulations and Compliance Manual, and conduct periodic training for all employees to raise their compliance awareness. Online training sessions are held twice a year on themes such as compliance with laws and regulations and human rights, anti-corruption, and alerts regarding fraudulent land dealings. We aim to further raise awareness of compliance through interactive communication, such as asking employees to submit written comments on training videos.

Compliance Manual (Cover and table of contents)

  • SAMTY’s Management Philosophy
  • Code of Conduct for SAMTY Employees
  • SAMTY’s Legal Compliance System
  • Compliance Items
    1. Respect for human rights and prohibition of discrimination, sexual harassment, harassment related to pregnancy, childbirth, childcare leave, nursing care leave, etc., and power harassment
    2. Compliance with various business laws and other laws and regulations
    3. Prohibition of bribery and gifts/entertainment, etc.
    4. Insider trading regulations
    5. Response to antisocial forces
    6. Compliance with the Road Traffic Act
    7. Appropriate use and management of information
    8. Proper accounting procedures and appropriate disclosure of company information
    9. Prohibition of acts against interests
    10. Dealing with troubles
Compliance Manual (Cover)
DFF Inc.

Whistleblowing System

Whistleblowing System

In order to ensure compliance with laws and regulations, prevent and detect corruption and corrupt practices at an early stage, and improve self-cleansing function, the Group requires anyone who becomes aware of any violation of laws or regulations to report such violations to the Company, and has put in place a whistleblowing system through the compliance consultation counter that enables employees to report and consult with internal and external organizations.
In operating the system, we have established whistleblowing management regulations, which stipulate strict confidentiality and prohibition of disadvantageous treatment of users, to provide a safe and easy environment for whistleblowers to report incidents. In FY2021, as a result of investigations and corrective actions taken in response to all reports, there was no case of serious human rights violations or violations of the anti-corruption policy.

DFF Inc.

Information Security

Information Security

Due to the necessity of business operations, each of our businesses handles a large amount of personal information, and the management and all employees of the Group are strongly aware of the social responsibility of information security in their duties. We have established an Information Security Committee consisting of representatives from each department, formulated the Information Security Basic Policy in 2006, and the Personal Information Protection Policy in 2007, and are working to establish and maintain an appropriate management system that includes the protection of all information assets and personal information handled by the Company. We also conduct an annual information security confirmation test for all employees.

DFF Inc.

Anti-Corruption Initiatives

Anti-Corruption Initiatives

The Company has established the Compliance Regulations that prohibit all corrupt acts, including bribery, and the contents of its policies and regulations are disseminated to all employees of the Company through online training programs utilizing the Compliance Manual. Furthermore, in order to ensure the appropriateness of business operations, the Corporate Planning Department, the division in charge, receives various reports at affiliate company meetings, etc., held in accordance with the Affiliate Company Management Regulations, and provides advice on compliance and risk management matters to the Group companies as necessary.
The Group companies operate their businesses based on the division of duties and authorities determined by each company, while directors are dispatched from the Company to important companies of the Group to supervise their business operations. Meanwhile, the Internal Audit Department audits the Company’s group management system as well as important companies of the Group, and reports the results to the Representative Director and President, the Board of Directors, and the Board of Corporate Auditors, thereby implementing group-wide anti-corruption measures.
In FY2021, there was no case of bribery or other corrupt or anti-competitive behavior and no employee dismissal.

DFF Inc.

Insider Trading Prevention Initiatives

Insider Trading Prevention Initiatives

In accordance with the Internal Information Management Regulations, we appropriately manage undisclosed insider information and ensure fair information disclosure in dialogues with shareholders. Moreover, the Company’s Compliance Manual clearly stipulates the prohibition of acts that violate the insider trading regulations, and training is provided to all our employees to prevent insider trading through regular educational activities.

DFF Inc.

Exclusion of Relationships with Anti-social Forces

Exclusion of Relationships with Anti-social Forces

We recognize that any connection with anti-social forces will seriously damage society’s trust in a company and have a serious impact on the company’s continued existence. Our Compliance Regulations and Compliance Manual stipulate that we shall resolutely confront anti-social activities and forces and shall not have any relationship with them, and we are committed to eliminating anti-social forces.
The Human Resources & General Affairs Department oversees the prevention of damage caused by anti-social forces and the elimination of relationships with them. In accordance with the Regulations for Investigating Interested Parties and the Manual for Dealing with Anti-social Forces, the Department works to ensure that all employees are aware of how to deal with anti-social forces in daily business activities, and investigates the credibility of shareholders, officers, employees, business partners, and others involved in corporate activities to eliminate the intervention of anti-social forces. Furthermore, in cooperation with lawyers, police, and other authorities, we strive to develop and strengthen a system to block any relationship with anti-social forces.

DFF Inc.

Anti-Money Laundering, Counter Financing of Terrorism, and Counter-Proliferation Financing

Anti-Money Laundering, Counter Financing of Terrorism, and Counter-Proliferation Financing

As a real estate transaction agent and a Type II Financial Instruments Business Operator, we have positioned Anti-Money Laundering, Counter Financing of Terrorism, and Counter-Proliferation Financing (hereinafter referred to as "money laundering, etc.") as one of our important issues of management, the Company will establish a management system and implement measures in accordance with the risk-based approach under the leadership of the managements, based on the Act on Prevention of Transfer of Criminal Proceeds, and other related laws and regulations, as well as guidelines issued by relevant ministries and agencies.

In addition, in order to respond to changes in increasingly complex and sophisticated money laundering and other risks, the Company will consider necessary revisions within the PDCA cycle.

SAMTY, DFF Inc.

Compliance Consultation and Reporting Desk for Business Partners

Compliance Consultation and Reporting Desk for Business Partners

The Samty Group has established a Compliance Consultation and Reporting Desk to enable directors and employees of its business partners to consult with and report any compliance violations by the Group.

User

Directors and employees of business partners doing business with the Samty Group companies

Subject of consultation and reporting

Consultation and reporting of any and all matters relating to non-compliance (including possible non-compliance) by any of the SAMTY Group companies

Correspondence desk

Compliance Management Division, SAMTY Co., Ltd.

How to consult or report

Please use the Consultation/Reporting Form at the bottom of this page for consultation and reporting.
When consulting or reporting, please be sure to include the name of your employer and department, your name and e-mail address, and the content of your consultation or report.
Please be as specific as possible in the Details of Consultation/Reporting section, including the specifics of what was said or done, when, where, by whom, to whom, and how, as well as the frequency.

Protection of the informant

  1. Personal information provided will be used only to the extent necessary for investigation and response and handled in strict confidence.
  2. The content of the consultation or report will be shared only with the minimum number of parties involved for investigation and response.
  3. We will never treat the informant or business partner in a disadvantageous manner for the reason that the informant or business partner consulted or reported the matter. Any disadvantageous treatment of any person for consulting or reporting is prohibited by the internal rules, and violators will be punished strictly.

Note

We do not accept false reports, reports that are intended to slander or defame others, or reports for business purposes.

When you agree with the above, please click the Consultation/Reporting Form to consult with us or report a case.

DFF Inc.