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Sustainability

Compliance

In our company, we consider compliance to be one of the most important challenges in management. We view compliance not only as adhering to legal regulations but also encompassing corporate ethics and social norms. Our business activities are built upon the trust of our customers and society, and we believe that this trust forms the very foundation of our business.

The Orico Group Code of Conduct

We consider conduct risks that could impair corporate value to be significant management risks. Taking into account current societal demands, we revised "The Orico Group Code" in 2022 as a new code of conduct to guide "right actions" from a societal perspective, and we are committed to promoting fair corporate activities.

オリコグループにおけるコンプライアンスの定義

Compliance System

  1. Compliance Committee
    Established in October 2000 with the aim of promoting compliance in our company and group companies and improving corporate value as a company contributing to society, the Compliance Committee is composed of a chairperson, vice-chairpersons, and standing members. The standing members include lawyers from outside our company. The committee discusses and examines issues and problems related to overall compliance in our group and a wide range of measures to ensure that compliance permeates and takes root in our company. The contents of the Compliance Committee are reported to the President and Director and the Board of Directors promptly and appropriately, and the Board of Directors supervises the Company's compliance system.
  2. Corporate Compliance Group
    The Corporate Compliance Group, consisting of the Compliance Administration Department (Compliance Office and AML Office) and the Legal Department, plays a central role in promoting and establishing compliance within our Group. Specifically, the Corporate Compliance Group is in charge of assessing the risk of all forms of corruption, including money laundering, insider trading, and bribery, identifying corruption early, and preventing its occurrence in collaboration with other departments.
    The Corporate Compliance Group oversees our Group's compliance activities and serves as the secretariat for the Compliance Committee and the internal reporting system (Orico Helpline). The Corporate Compliance Group also maintains an internal control system to ensure proper business operations in accordance with laws, regulations, and internal rules. The Compliance Office is responsible for planning and formulating measures to deal with antisocial forces, strengthening cooperation with external specialized agencies, planning and formulating education and training programs to prevent any relationship with antisocial forces, and collecting and managing information on antisocial forces and crimes.
    The AML Office was newly established as a specialized department for the purpose of further strengthening our anti-money laundering and anti-terrorist financing measures. The AML Office oversees the prevention of money laundering and terrorist financing, collects information on regulatory trends, provides training to officers and employees, and handles other important new cases that may arise
    The Legal Department, as a department specializing in corporate legal affairs, is in charge of overall legal checks, as well as preparing training materials and providing information on legal matters.
コンプライアンス体制図

Internal Reporting System

Internal Whistleblowing System (Orico Helpline)

We and our group companies have positioned compliance (observance of laws, ethics, and other relating matters) as one of the most important management issues. To enhance compliance management, promote fair corporate activities, and improve corporate value, we have established the "Orico Helpline" as an internal and external whistleblowing/consultation window to detect and address violations and potentially violative actions at an early stage, enhancing the company's self-purifying function and striving to prevent fraud and misconduct.

The Orico Helpline allows employees, their family members, and retirees to report or consult about corrupt, illegal, or potentially corrupt acts, including bribery, without anyone knowing. The Orico Helpline is designed to enhance the company's self-cleansing mechanism and to prevent fraud and misconduct by identifying information on possible compliance violations at an early stage and taking countermeasures.

Of the whistle-blowing cases, those deemed important by the head of the Compliance Group are investigated by the Audit and Supervisory Committee to further strengthen governance. As a measure to spread the whistleblowing system, we have created helpline mobile cards, posters, and user guides, and are working to make known contact information, reporting methods, and reporting targets (fraud, procedural violations, information leakage, harassment, collusion prevention). In addition, we are working to improve employees' compliance awareness through information posting on the internal intranet and level-specific training.

Protection of Whistleblowers

At the Orico Helpline, we are making efforts to establish a system that employees can use with peace of mind, such as prohibiting disadvantageous treatment of reporting employees, thoroughly maintaining confidentiality regarding reports, and setting up external windows that can respond to telephone reports even on holidays and weekday nights. The operation status of the helpline is regularly reported to the Compliance Committee.
Detailed records of reports to the Orico Helpline can be found on the following page: https://www.orico.co.jp/company/corporate/customer_engagement/

Compliance Initiatives

Efforts to Ensure the Effectiveness of The Orico Group Code of Conduct

  1. Initiatives to Ensure the Effectiveness of The Orico Group Code Voluntarily by Executives and Employees
    We firmly believes that compliance is not just about adhering to various laws, regulations, and internal rules but also about embodying 'Correct Behavior' from society's perspective. To this end, we are promoting various initiatives to create an organization that encourages executives and employees to voluntarily report and inform us when they see or hear of corrupt acts or other conduct that does not conform to The Orico Group Code.
  2. Organizational Efforts to Ensure the Effectiveness of The Orico Group Code
    To ensure that our executives and employees work voluntarily towards compliance, we regularly conduct self-assessments (SA), compliance audits, and operational audits to systematically investigate, review, and identify corrupt practices or violations of The Orico Group Code.
    We also conduct corruption risk investigations for new transactions and investments.

The results of compliance violation investigations are regularly reported to the Executive Management Meetings and the Board of Directors. In addition, as a follow-up to the identification of suspected compliance violations, the Compliance Administration Dept. holds "The Orico Group Code Response Liaison Meeting" to identify and share information on the event, management report, make administrative reports, determine whether the conduct is not by The Orico Group Code, personnel report, and manage the case, as necessary. The Orico Group Code stipulates that our Group shall follow up on such matters as required. These follow-up procedures are provided to all executives and employees in Japan and overseas in a detailed and explained format in Japanese and English. They are disseminated along with The Orico Group Code through internal media.

In addition, to ensure the effectiveness of The Orico Group Code itself, we also check the Code from time to time when considering the organization's direction, such as when formulating various strategies, policies, and plans.

Cultivation of Compliance Awareness

Education & Training

Our group-wide training programs, differentiated by rank and position, always include compliance training, and we continuously work on employee education to enhance the penetration and establishment of compliance throughout the company.
In addition, once a year, we conduct e-training for all executives and employees of the Group to check their understanding and penetration of The Orico Code of Conduct to ensure compliance with the code at the individual level.

①Compliance Top Seminar

To promote the penetration and establishment of compliance, understanding and strong leadership from the top management are necessary. At Orico Group, we host "Compliance Top Seminars" for executives of Orico and executives of group companies. We invite attorneys and specialists in compliance & CSR (Corporate Social Responsibility) to these seminars to provide lectures on compliance management.

②The Orico Group Code Training

We analyze the causes of past violations, share attitudes needed for prevention, and conduct company-wide in-house training aimed at creating an open work environment that prevents non-compliance with the The Orico Group Code.

Spreading Awareness

Compliance Guidebook

To practice compliance, we clarify in an easy-to-understand manner the "attitudes and stances" required, the "initial responses" all staff should know, and "what we need as we work in the Orico Group". As a training tool that staff can learn autonomously, we have created a "Compliance Guidebook" and distributed it to all staff in the Orico Group for use in workplace training.

Compliance DVD

We use a Compliance DVD as a teaching material for new employee training and on-the-job training in the workplace, contributing to the penetration and establishment of compliance within the Orico Group.

Promotion of Various Qualifications

We promote the acquisition of various qualifications that form the foundation for practicing compliance.

Sustainability