Strengthening and Promoting the Compliance System

Basic Approach

We established a compliance manual in 2005 as a set of guidelines for daily operations. Every SWS Group employee is expected to adhere to the guidelines in the spirit of acting under the highest ethical standards. Compliance Committee meetings, chaired by the director in charge of legal affairs, are held on a regular basis to reinforce this effort through the planning and implementation of measures that ensure business operations are being conducted legally and ethically and compliance risks are being identified, analyzed and dealt with. We also developed a worldwide legal risk reporting system to obtain and understand potential or identified legal risk both quickly and comprehensively within each Group company and to act promplty when addressing them.

Promotion System

Contacts for compliance reporting were established as an effective system for the early detection and correction of any incidents of legal or ethical non-compliance. To make filing reports easier, we set up an internal contact run by our Legal Department as well as an external contact operated by our corporate legal counsel. Reports of non-compliance are mainly investigated and handled by the Compliance Committee Secretariat. In fiscal 2018, 18 incidents(12 internal and 6 external) were reported, investigated and appropriately addressed.