Compliance

Basic Approach

Guided by our management philosophy and code of conduct, we strive to “be candid and sincere” and to strictly comply with legal and regulatory requirements and in-house rules. To communicate these principles throughout Prima Meat Packers Group, we have prepared a guidebook outlining behavioral expectations. Furthermore, we designate October “compliance-strengthening month” every year to foster a compliance mindset in employees. During the month, our whole group tackles this. For example, we send out a compliance-related address from the president, display compliance-related posters, and hold compliance-related workshops.

As part of our efforts to entrench compliance culture, we conduct regular compliance-awareness surveys among employees of Prima Meat Packers Group to monitor the level of compliance and obtain findings to guide the development of compliance measures.

Compliance Program

Prima Meat Packers has a compliance-related body called the Compliance Committee, which meets regularly and is attended by senior managers. The Compliance Committee discusses and resolves key compliance-related matters, including the status of the response to compliance incidents that have occurred within our group, the progress made in addressing compliance-related tasks, and our policy for future efforts.

In addition, we have positioned the presidents of Japanese and overseas group companies as chief compliance officers to promote a compliance structure over our entire group. The chief compliance officers attend the regularly held Leaders’ Liaison Council for Compliance. The purpose of the council is to communicate across Prima Meat Packers Group the status of the response to compliance incidents that occurred within the group and the progress made in addressing compliance-related tasks.

Main Actions

Training Programs to Foster a Culture of Compliance

To raise awareness of compliance, we provide general compliance training as well as training for preventing workplace bullying, sexual harassment, and pregnancy and maternity-leave discrimination (known as “maternity harassment” in Japan). The general program is led by the staff from the Legal Department, while the latter program is led by a professional instructor. Both programs are delivered at our workplaces across Japan in person or remotely (using videos we distributed and a web conferencing system). We also include compliance content in our training program for new employees and in our rank-specific training programs, and communicate compliance information in our internal newsletter.

Whistleblower Hotline

We provide an internal and external whistleblower hotline for raising compliance concerns related to group operations, such a legal violation, violation of an in-house rule, malpractice, or a serious breach of corporate ethics. For concerns related to workplace bullying or sexual harassment, Prima Management Service provides a dedicated service called the PMS Hotline & Helpdesk. The helpdesk has female staff on hand to provide support by telephone or email to women who have experienced harassment. We also work with external experts to provide swift organizational support for employees who experience mental health problems.

Reports and inquiries can be made anonymously. Whistleblowers’ privacy will be safeguarded, and all efforts will be made to ensure that whistleblowers are not penalized for using the hotline. To raise employee awareness about the hotline and make it more accessible, we advertise the hotline in posters and on the intranet, and provide employees with cards containing the hotline information.

Hotline services

When an eligible user contacts any of the four hotline channels, the notification is sent to the General Manager of Legal Affairs and the Director in charge of Compliance and General Affairs.

Preventing Insider Trading

To prevent insider trading, we annually issue a directive to review the provisions concerning the control of inside information and restriction on insider trading. Managers from division heads upward are registered on the Japan Securities Dealers Association’s Japan-Insider Registration & Identification Support System (J-IRISS). Brokers can cross-check individuals on this database to preempt the risk of insider trading.