We at Roland have established “Compliance Guidelines” as our fundamental principles and have made them known to everyone in the Group. We will continue complying with various laws, regulations and rules related to our business activities so that we will be able to appropriately respond to the social requirements corresponding to revision of laws and regulations or environmental changes.
Compliance Promotion System and Activities
Compliance Promotion System
The Risk Management and Compliance Committee, consisting of the Company's executive officers, corporate auditors, and key executives of the Group, meets quarterly to promote compliance throughout the Group by determining policies for Group-wide compliance promotion activities and confirming compliance promotion activities at a regional level.
The Group as a whole has designated Competition Law and Personal Information Protection Law as important laws and regulations to be managed, and confirms the status of compliance with these laws and regulations as well as related promotion activities. In addition, we have appointed compliance promotion leaders for each region, and each leader, in accordance with the policies of the Risk Management and Compliance Committee, selects the regional important laws and regulations to be managed and conducts compliance promotion activities based on the actual conditions of each region.
Matters reported to the Risk Management and Compliance Committee are also reported to the Board of Directors.
Compliance Training
We provide various training programs through face-to-face group training and online learning. New employee training provides an opportunity to learn about Compliance Guidelines and the basics of compliance. To ensure fair trade and healthy competition, we also provide training to relevant departments on the Anti-monopoly Law, the Subcontract Law, and the Law against Unjustifiable Premiums and Misleading Representations. Regarding the Anti-monopoly Law, after consulting with outside experts, we have established internal guidelines for communication between our sales representatives and business partners, which are regularly reviewed and disseminated to raise awareness of compliance. Education is also provided at our sales subsidiaries by formulating “Competition Law Code of Conduct”, training on competition law, personal information protection, etc. led by the legal department in subsidiaries, and compliance-related content posted on the intranet. At our overseas manufacturing subsidiaries, anti-bribery rules and regulations are formulated, and it is ensured that all employees are aware of them. When necessary, the top management of manufacturing subsidiaries send out messages of caution and repeatedly confirm them at meetings to ensure the prevention of bribery and other corrupt acts, and to maintain healthy relationships with political and administrative authorities and business partners.
Whistle-blowing System
We have established a whistle-blowing system to enable our employees to report or consult on any misconduct or potential misconduct by our directors, corporate auditors, executive officers and employees for the purpose of early detection, correction, and prevention of recurrence of organizational or individual misconduct, etc. In addition, a global whistle-blowing system has been established to enable employees of oversea subsidiaries to report or consult with the Company, the parent company, regarding misconduct or potential misconduct by directors, officers of oversea subsidiaries. To improve the accessibility and reliability of these systems, both internal (corporate auditors) and external (law firm) contact points have been established, anonymous reporting is accepted, and rules for information management regarding the reporting have been clearly set. Group companies have also established their own reporting systems which meets local conditions, for early detection of misconduct.
In addition, we have established a workplace consultation contact which employees can consult issues in the workplace, such as harassment.
We will continue to operate these systems and activities appropriately to prevent or detect compliance violations at an early stage. In the event of a compliance violation, we will strive to accurately identify the facts and the cause. We will then take the facts seriously, take thorough measures to prevent recurrence, and deal with the violating employee in a strict manner, including appropriate disciplinary action.
Compliance with Other Laws and Regulations
Tax Compliance
It is our basic principle that, in developing business globally, we will comply with tax-related laws in various countries or areas around the world to properly pay taxes and to assume the social responsibilities a corporation should undertake. We are paying due attention to any changes in the taxation systems in all operating countries or areas, and we continue to be deeply aware of compliance to applicable laws and regulations. At the same time, we are ready to make use of the preferential tax system that may apply to our business activities, to meet with the taxation challenges backed by the support by external experts.
To meet the risk of transfer pricing tax in various countries or areas (the risk of additional taxation being deemed that the allocation of income between affiliates has been unjustly manipulated with improper prices at which the transactions have been effected), we do our operations after establishing the policy for the transfer prices and, if necessary, make use of the APA (Advance Pricing Arrangement: the system for receiving advance confirmation from tax authorities concerning the appropriateness of the price at which the transactions between affiliates are effected), in an effort to make the transaction prices be appropriate. If additional taxation occurs, we are endeavoring to exclude the double taxation (i.e., both countries impose taxes on one taxation factor), making use of the mutual agreement procedure (consultation between the governments by the tax authorities of both countries) and other measures.