Counselee · whistleblower protection priority

Counselee · whistleblower protection priority

The company prioritizes protecting the counselee·whistleblower’s identity·personal identity and counselee·whistleblowing does not give disadvantages due to counselling·whistleblowing.

Identity disclosure and personal protection

Identity disclosure and personal protection

The head of the ethical management department and the staff must ensure that the identity of the counselee/whistleblower and the person who cooperated with the investigation is not exposed during consultation/receipt of report/investigation/follow-up process and protect them from personal issues.

As such, we comply with the following.

1. ① During the entire process of receiving information/investigation/reporting, the name of the counselee/whistleblower should not be used for record management, and the contents that may be used to identify personal information should be minimized.
2. ② Relevant records are not disclosed outside the ethical management department..
3. ③ However, in cases where cooperation with the internal accounting management department is required during counselling/whistleblowing related to the internal accounting management system, the contents may be shared as an exception.

Investigation is carried out carefully so that the identity of the counselee/whistleblower is not exposed.

If the possibility of exposure increases, the investigation is immediately stopped, and resumed after establishing and implementing measures to prevent exposure.

Disciplinary action for violation of identity/personal protection

Disciplinary action for violation of identity/personal protection

If the head of the ethical management department or department staff leak the identity or details of the counselee/whistleblower and the person who cooperated with the investigation, violation of ‘identity exposure and personal protection’ is applied, and disciplinary action will be taken in accordance with the relevant regulations.

However, exceptions may be granted under following conditions.

1. ① Matters that may cause serious personal safety accidents and business stoppage
2. ② Significant irregularities, leaks of company secrets, forgery/falsification of data, media reports, etc.
3. ③ Staff must not engage ethics management department to inquire about the identity of the whistleblower or engage in any actions that enables disclosure of identity, such as investigation. Unfair actions such as giving disadvantage or discrimination manipulating working conditions to those who fairly counselled/provided information is prohibited.

Organizations or individuals who violate the above are subject to personnel disciplinary action in accordance with Article 3, Paragraph 5 of the code of ethics.

Operating leniency and reward system

Operating leniency and reward system

If the counselee/whistleblower participated in the misconduct, but counselled/reported the incident, the company may take into consideration of such circumstances when punishing or giving disciplinary actions.

In addition, the company may reward the counselee/whistleblower if it has contributed to the company’s profit or enhanced the value through the counseling/whistleblowing.