Compliance/Risk Management

Compliance

Believing that compliance including anti-bribery and anti-corruption is a prerequisite for all corporate activities, the Glosel Group (hereinafter referred to as the “Company”)
has established the Compliance Manual by itself and the Compliance Committee chaired by the President, Representative Director to ensure thorough compliance.
In addition, we have established policies and manuals concerning the elimination of antisocial forces, whistleblowing system, protection of personal information, and Individual Numbers, and conduct compliance education for all employees.

Basic Policy

Compliance is defined in the Company’s Basic Philosophy and Management Philosophy, and the Company places compliance as a basic management policy.

Basic Philosophy: Creation & Innovation

The Glosel Group will focus on contributing to the development of industry in Japan (related to electronics) through the constant practice of “Creation & Innovation,” while strictly obeying all laws and aiming for harmony with society. We will strive to provide products and services that match customer needs and aim to satisfy and inspire our customers. We declare our basic management policy to become a company that is most supported and trusted by customers and gains the understanding and affinity of its shareholders through its sound results and transparent corporate management.

Management Philosophy: Cornerstone of Corporate Activity

Revised: April 1, 2009

Promotion Organization

The Glosel Group has established the Compliance Manual with the director as the responsible officer and has established the Compliance Committee. In addition, the Group maintains confidentiality of reports made by directors and employees in the event that they found any misconducts that violate laws, regulations, the articles of incorporation, etc., and does not treat whistleblowers disadvantageously. The Compliance Committee meets twice a year to report on compliance and discuss responses. Any significant non-compliance event is reported to the Compliance Committee, which includes all members of the Board of Directors, and is supervised by the Board. Furthermore, the Auditing Department has been established in the Glosel Group to secure, maintain, and improve the internal audit system, and to enhance the compliance system by conducting internal audits. In addition, the Legal Department has been established in the Glosel Group to collect information, raise awareness, educate, and consult on legal affairs and compliance, and respond to whistleblowing.

Whistleblowing System

The Glosel Group has established the Whistleblowing Manual in compliance with the Whistleblower Protection Act and established whistleblowing hotlines in the Company (Human Resources & General Affairs Division) and outside the Company (law office) to receive reports from our group officers and employees regarding misconduct within the Group. Additionally, the Company has designated personnel in charge of whistleblowing, conducted investigations, taken measures to protect whistleblowers and prevent them from being treated disadvantageously, and provided education. Through these efforts, we are striving to prevent, detect, and promptly take corrective measures against misconducts. The acts subject to whistleblowing include violations of laws and regulations, violations of internal rules, acts that significantly affect the reliability of financial reporting, violations of corporate ethics, and any other acts that reduce the social credibility of the Glosel Group.

Education and Training

To raise awareness of compliance and prevent problems from occurring, the Glosel Group conducts the following education, training, and awareness activities.

Export Control

For the purpose of contributing broadly to the maintenance of international peace and security through compliance with trade-related laws and regulations in export transactions, we establish a necessary management system for trade in goods and technology, which is regulated by the Foreign Exchange and Foreign Trade Act (hereinafter referred to as the “Foreign Exchange Act,” including cabinet/ministry ordinances and public announcements and notices of the Ministry of Economy, Trade and Industry related to the Foreign Exchange Act), and appropriately implement security trade management

Basic Policy for Eliminating Antisocial Forces

We have established the following policies to realize and thoroughly fulfill the corporate social responsibility (CSR).

Established: April 1, 2011

Anti-corruption Initiatives

The Glosel Group has implemented the following initiatives to prevent corruption, including bribery.

Status of Non-compliance

Non-compliance cases are to be confirmed through internal audits by the Internal Audit Department, in addition to reports to the Human Resources & General Affairs Division and whistleblowing. In fiscal 2022, two non-compliance cases (including one whistleblower case) were found out at the Glosel Group. All of them were minor, and the relevant persons were subject to punishment.

Risk Management

With regard to risk management, the Glosel Group has established the Crisis Management Manual to ensure early response and prompt corrective action when signs of risk are detected by establishing the Crisis (Risk) Management Committee, chaired by the President, Representative Director to thoroughly eliminate risks. In addition, from the viewpoint of information security and thorough export control, we have established the Information Security Policy and Manual as well as the Security Export Control Manual and are taking necessary measures to prevent accidents.

Risk Management Structure

The Glosel Group has established the Crisis Management Manual and holds regular meetings of the Risk Management Committee chaired by the President, Representative Director to confirm the scope of the crisis, the development of the risk catalog, etc., and the operational status. In addition, for each of the priority risks (i.e., disaster and accident risk, compliance and CSR risk, and sales risk), a department has been designated to manage the progress of company-wide risk management. The content of management is reported to the Risk Management Committee, which includes all members of the Board of Directors. In addition, we have formulated the Business Continuity Plan (BCP) to prepare for emergencies both inside and outside the Company.

Risk Assessment

At the Glosel Group, the following actions are taken.

Major category Risk item Anticipated risk Risk assessment
A. External environment

E.g., Disaster damage in our company

E.g., Delay in delivery

Probability of occurrence, impact, and overall
rating are evaluated on a three-level scale

B. Business activities

E.g., Product liability

E.g., Compensation liability

Same as above

C. Internal environment

E.g., Outflow of human resources

E.g., Information leakage

Same as above

Information Security Policy

Glosel Co., Ltd. (hereinafter referred to as the “Company”) recognizes the importance of information security, protects the information assets received from customers and business partners and of the Company from threats such as accidents, disasters, and crimes, and implements information security based on the following policies to respond to the trust of society as a company trusted by customers and business partners.

Established: September 14, 2022

Business Continuity Plan

As part of its corporate social responsibility, the Glosel Group has formulated a Business Continuity Plan (BCP) to minimize the impact on our business partners and society by restoring our system for supplying products after major disasters (earthquakes, wind and flood damage, fires, pandemics, etc.). The main measures are as follows.

Privacy Policy (Personal Information Protection)

As a semiconductor technology trading company with strengths in providing outstanding products and cutting-edge technologies, Glosel (hereinafter referred to as the “Company”) fully respects the protection of the personal information of customers, business partners, directors, and employees (including fixed-term employees, advisors, part-timers, contract employees, temporary staff, etc.), and strives to establish and thoroughly implement an appropriate management system, aiming to realize a future society that is easy for people to live in. The Company hereby establishes the Personal Information Protection Policy below, disseminates its directors and employees about it, and complies with it.

Glosel Co., Ltd.

Proper Tax Payment

The Glosel Group operates globally and believes that it is the responsibility of the Company to fulfill the tax obligations appropriately in the countries and regions where we operate. Based on this recognition, Glosel’s Finance Division and the Group subsidiaries work together to ensure proper tax management by complying with the following statements, and to enhance corporate value throughout the Group.