Compliance

Compliance Declaration

The Lion Group's strong reputation for trustworthiness has been built through decades of hard work by its employees. The trust the Group enjoys has been a key driver of its growth and development. As our operating environment continues to undergo profound changes, we strongly believe that it is necessary to clearly lay out the principles that anchor our behavior, which we have honed over years of operations, in a Code of Conduct. We must create and maintain a framework that will ensure that each and every person working in the Lion group understands and is able to carry out their responsibilities.

Compliance means obeying laws and regulations as well as maintaining a strong ethical grounding in order to satisfy the expectations and needs of customers and other stakeholders while fulfilling our role as a public entity. We regard ethics as meaning, broadly, doing what is right. In concrete terms, we see this as rooted in being honest, observing social mores, not antagonizing others, and thinking of others as we think of ourselves. Based on this understanding, we established the Lion Group Charter for Corporate Behavior in 2003.

We have updated the Lion Group Charter for Corporate Behavior in light of changes in society. The Behavioral Guidelines contained therein now more clearly define our stance with regard to providing safe, secure products and services, addressing environmental issues and other topics.

We hereby once again declare our commitment to upholding the Lion Group Charter for Corporate Behavior and ensuring that the Company is useful and valuable to society.

January 1, 2008

Approach

The Lion Group Charter for Corporate Behavior and the Behavioral Guidelines form the foundation of the Lion Group’s compliance framework. The Corporate Ethics Committee, chaired by the director responsible for corporate ethics, works proactively to foster compliance awareness within the Lion Group. The Lion Group Charter for Corporate Behavior and the Behavioral Guidelines are distributed in pamphlet form to all employees and publicly available on Lion’s website.

The Lion Group has established the LION Anti-Bribery Principles in light of developments around the world related to the strengthening of legal regulations against acts of bribery and corruption. Regarding taxation, the Group has established the Lion Group Tax Policy, stipulating that the Group shall practice highly transparent tax treatment and appropriately fulfill its tax obligations.

Harassment Prevention

The Lion Group Charter for Corporate Behavior states that “We shall promote fair treatment and respect the diversity, individuality and personalities of our employees. We shall ensure a safe and comfortable workplace to realize the mental and physical well-being of our employees.” Accordingly, Lion prohibits sexual harassment as well as all other forms of workplace harassment, including those related to pregnancy, childbirth, childcare leave and nursing care leave.

Furthermore, to prevent the occurrence of harassment, we have formulated the Harassment Prevention Declarations, which define and provide examples of harassment. We are promoting widespread awareness of the Declarations among employees via the Company intranet and through regular e-learning training and other educational activities.

The Declaration applies not only to regular employees, but to everyone who works at Lion, including contract, part-time and temporary employees. The Lion Group strives to prevent and respond appropriately to harassment not only among employees, but also that involving customers and business partners.

Established Compliance Consultation/Notification Window (AL Heart Hotline)

Lion has set up an internal and external whistle-blowing system, the AL Heart Hotline, as a set of contacts for consultations for use when an employee learns of a compliance violation and ordinary reporting routes within the workplace are inadequate or unusable.

Framework and system

When the AL Heart Hotline receives a consultation or report, we confirm the details of said report and the response desired by the reporter, and the director of corporate ethics investigates and confirms the facts of the matter. If a problem is detected, steps are taken to seek solutions and resolve it. During this process, the privacy of both the employee who used the hotline and the employees involved in the matter reported is protected, and strict confidentiality is maintained regarding the investigation. We take steps to ensure that employees who make reports or cooperate in investigations will not be treated disadvantageously.

All consultations and reports received by the Hotline are reported to the Corporate Ethics Committee,* and matters are also reported to the Board of Directors as needed. Furthermore, except in the case of anonymous reports or other such circumstances, feedback is provided to all consulters and reporters.

The AL Heart Hotline System

The AL Heart Hotline System

* An independent, Group-wide committee that promotes specific measures related to improving the compliance framework and spreading and reinforcing compliance awareness.

AL Heart Hotline

In LION Group, when the Group's employees or customers become aware of any conduct in actual or suspected violation by the Group or its employees of laws or corporate ethics (LION Group Charter for Corporate Behavior or Behavioral Guidelines), or otherwise wish to consult about any other ethical problems, they are entitled to consult with or notify to the in-company or external notification (whistleblowing) window (AL Heart Hotline).

Notification (Whistleblowing) Window

1. Person responsible for corporate ethics in the company
Adressee of documents 1-3-7, Honjo, Sumida-ku, Tokyo 130-8644 Japan
“Attn: Person responsible for corporate ethics, Auditing Office, Lion Corporation”
Email address (for this purpose only) ethics@lion.co.jp
2. External attorney
Adressee of documents 5F, Eiha-shinkawa, 1-5-17, Shinkawa, Chuo-ku, Tokyo 104-0033 Japan
“Attn: Attorney-at-law, Shuji Yamaguchi Okabe & Yamaguchi Counselors at Law”
Email address (for this purpose only) al-hot@olo.gr.jp

Persons eligible to use the Hotline

  • The Hotline is available not only for the Group’s regular employees but also for the Group’s all workers including casual employees (such as part-time employees), dispatched employees and contracted employees as well as those who have transactional or any other relationship with the Group.

Method of consultation and notification

  • To identify the contents precisely, if possible, please consult or notify in a document or by email.
  • To enable sufficient and prompt identification of facts as well as feedback of investigation results and future actions, please disclose the identity of the notifying person (name, department, company name). Note that, in the event of notification on an anonymous basis, the factual investigation may become insufficient, and further that such feedback will not be possible. Also, when notified to an external attorney, the notifying person may request for masking of his/her name when being transferred to the person in charge of corporate ethics in the company.
  • As regards the contents of such consultation and/or notification, please describe the relevant acts of violation of laws or corporate ethics in as much detail as possible, by specifying “when” “where” “who” “what” “for what purpose” “how”, and “what are the consequences”.
  • Reporting form

Flow after receiving consultation and/or notification

  • We will promptly verify the facts through the consulting and/or notifying person, and then evaluate the seriousness of the factual details. Depending on the nature of the case, it will be reported to the top management.
  • After factual investigation, if certain non-compliant acts have been established, we will, under the top management’s knowledge sharing and instructions, take steps towards settling the shape, resolving the issues, and then taking remedial actions for prevention of recurrence. Also, the violators will be strictly sanctioned.
  • The window receiving the consultation and/or notification will feedback the relevant consulting and/or notifying person.

Whistleblower Protections

  • The privacy of individuals who use the hotline for consultation or reporting as well as the privacy of those who are the subject of such reporting is protected.
  • The staff tasked with investigating and responding to consultations and reports maintain strict confidentiality regarding such consultations and reports and their content.
  • Individuals shall not be treated disadvantageously for having used the hotline for consultation or reporting.
  • Individuals shall not be treated disadvantageously for cooperating in investigations, etc.

Raising Awareness of the Hotline

We are taking steps to raise awareness of said system among all employees, including temporary staff. Furthermore, via the annual Compliance Awareness Survey for employees, we provide an explanation of the hotline and monitor its recognition rate among employees. The recognition rate was 99.5% in 2020.

The AL Heart Hotline Recognition Rate Among Employees
2017 2018 2019 2020
95.8% 98.5% 98.6% 99.5%

Consultation and notification

In 2020, the hotline received 73 consultations and reports. However, none of the cases were judged to constitute serious misconduct, and all were appropriately addressed and resolved.

The Lion Group makes informed estimates of the risk of human rights violations, such as abuse of authority by superiors or sexual harassment, at all Group departments. Based on these estimates, we implement education on harassment and other thoroughgoing measures tailored to each department with the goal of reducing such risk.
We also implement e-learning training on behaviors that constitute harassment for all employees as part of proactive harassment prevention.

AL Heart Hotline Consultations and Reports
2017 2018 2019 2020
Harassment 9 15 11 8
Personnel and labor management issues 5 6 11 7
Others 4 2 3 58

e-Learning Training

Lion conducts periodic e-learning. Topics covered in the mandatory Lion Career Village (LCV) e-learning curriculum in 2020 included a declaration of commitment to the Lion Group Charter for Corporate Behavior and other aspects of compliance (including harassment prevention), Lion’s conceptual approach to quality, social media-related risks, information management, basic knowledge of insider trading regulations, human rights, bribery and safety (including occupational accidents).

Compliance Awareness Survey

Every year, the Corporate Ethics Committee conducts the Compliance Awareness Survey,* which covers all domestic Lion Group employees (including part-time employees). This survey provides an assessment of compliance awareness at the individual employee level and a periodic evaluation of the effectiveness of compliance systems. In 2020, the survey was conducted for the 17th time. Approximately 91.8% of the targeted 4,334 employees responded. Matters identified as requiring a response through the opinions and other results gathered via the survey are dealt with promptly, and the survey results are reported to management, which then provides feedback to individual divisions.

Percentage of Employees Who Received Feedback from the Survey Results

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*Anonymous questionnaire survey covering such topics as compliance with the Lion Group Charter for Corporate Behavior, whether there was feedback from the results of the previous Compliance Awareness Survey, and awareness of the AL (All Lion) Heart Hotline.

LION Anti-Bribery Principles

LION Group will, in accordance with the global trend of reinforced legal regulations against the acts of bribery and corruption, set out the LION Anti-Bribery Principles with a view to preventing such acts of bribery and corruption and thoroughly requires the pursuit of business activities in compliance with all applicable laws of the countries and regions where we are conducting business.

Tax Transparency

The Lion Group strives to correctly understand both the letter and the spirit of tax-related laws and systems in the countries and regions in which it operates and to appropriately fulfill its tax obligations. To this end, the Group has established the Lion Group Tax Policy. By practicing highly transparent tax treatment and appropriately utilizing tax planning and tax incentives, the Group seeks to contribute to the development of local communities and increase its corporate value.

Initiatives at Overseas Group Companies

Anti-Corruption Measures at Lion Corporation (Thailand) Ltd.

To ensure honest, transparent and corruption-free business activities, Lion Corporation (Thailand) Ltd. (“LCT”) has been a member of the Private Sector Collective Action Coalition Against Corruption since 2014 and established an Anti-Corruption Policy in 2015. This policy prohibits the receipt of bribes and lays out rules to ensure the transparency of donations and other forms of support for external organizations.
LCT also implements measures to spread anti-corruption awareness among employees. At an anti-corruption event, top management spoke about the company’s anti-corruption commitment, and everyone in attendance provided their signature to create an anti-corruption board. Furthermore, the company had ballpoint pens inscribed with “Anti-Corruption” made and distributed to employees to remind them to think carefully about possible issues before signing contracts with external parties.

Anti-corruption board featuring the signatures of participating employees

Pens inscribed with “Anti-Corruption”

Compliance Initiatives at Southern Lion Sdn. Bhd.

Southern Lion Sdn. Bhd. (“SL”) in Malaysia distributes an Employee Handbook, containing its CSR policy and stance on human rights, to all employees. Furthermore, SL has prepared a Code of Conduct that includes the key elements of the Lion Group’s latest policies and works to ensure awareness of it among employees.

Employee Handbook

Employee Handbook

Principles for Corporate Social Responsibility

Principles for Corporate Social Responsibility

Hotline Initiatives at Lion Corporation (Korea)

Lion Corporation (Korea) (“LCK”) has operated a hotline for employees (including part-time and contract employees) as well as external stakeholders since 2004. Consultations made through the hotline are reported to the director in charge of ethics, the relevant officers and external consulting lawyers. Those using the hotline can choose to do so under their name or anonymously. The confidentiality of consultations is assured.

To promote awareness of the hotline, LCK notifies employees of the hotline as part of their compliance education and provides information on the hotline via the LCK website and company intranet.

Hotline Initiatives at Lion Daily Necessities Chemicals (Qingdao) Co., Ltd.

Since 2014, Lion Daily Necessities Chemicals (Qingdao) Co., Ltd. (“QDL”) has provided a hotline that employees can use in the event of a violation corporate ethics. An external Chinese law firm receives reports from the hotline, and the director of corporate ethics and other related QDL staff investigate reports and take action as needed. QDL promotes employee awareness of the hotline via postings on the company intranet.