Governance initiatives

The Group regards corporate governance as a management governance function for maximizing corporate value for all stakeholders and realizing the “Principle of Coexistence”. Its basic policy is to "always respond quickly to changes in the market environment" and "enhance management transparency."

(For more details, please refer to the Corporate Governance of Shareholder Investor Information)

We aim to realize coexistence and coexistence with various external environments surrounding our company, with "PALTEK Management Philosophy" as "symbiosis with diverse beings". In order to realize the "Principle of Coexistence", all directors and employees have high ethical standards, and for the purpose of re-recognizing the system to comply with laws and regulations and the Articles of Incorporation. Specifically, we are making the following maintenance.

"PALTEK Action Guidelines"

Directors and employees “on their own” have stated the following matters.

• Act in good faith and in compliance with laws and regulations

Establishment of "Compliance Basic Regulations"

Our officers and employees act in good faith according to the values ​​and ethics required of business people and working people, For the purpose of acting based on laws and regulations (including administrative laws and notifications), internal regulations and rules, corporate ethics and action guidelines, We stipulate the following items

• Responsibilities of officers and employees (compliance with laws and practice of ethical behavior)
• Prohibited matters (execution/instruction/implication/acquisition of compliance violation)
• Obligation to report when you know that you are in violation of laws, regulations, articles of incorporation, etc.
• Conduct prior compliance consultation
• Implementation of compliance training

Establishment of "Risk Information Communication Regulations"

Quickly detect violations of laws and regulations, articles of incorporation, action guidelines, risks, etc. (including information on actualization and possibility of actualization) in the company, The possibility of scandals leading to a loss of image of the company and loss of credibility, We have established a system to ensure the transparency of the organization by picking it at the “bud” stage and making the company's “self-cleaning” work smoothly.

Establishment of "Risk Information Communication Regulations"

Quickly detect violations of laws and regulations, articles of incorporation, action guidelines, risks, etc. (including information on actualization and possibility of actualization) in the company, The possibility of scandals leading to a loss of image of the company and loss of credibility, We have established a system to ensure the transparency of the organization by picking it up at the “bud” stage and making the company's “self-cleaning” work smoothly.

We aim to realize coexistence and coexistence with various external environments surrounding our company, with "PALTEK Management Philosophy" as "symbiosis with diverse beings". In order to realize the "Principle of Coexistence", all directors and employees have high ethical standards, and for the purpose of re-recognizing the system to comply with laws and regulations and the Articles of Incorporation. Specifically, we are making the following maintenance.

Establishment of "Risk Management Regulations"

Our risk range is compliance risk, strategy risk, operating risk, financial risk, accident risk, crime risk, rights risk, Personnel risk, disaster risk, information leakage risk, and other important matters related to the survival of the company are clarified, and the departments responsible for each risk are clarified. It stipulates the convocation when it becomes obvious, the composition of the countermeasure organization, and the specific work of risk response.

Establishment of “Risk Information Communication Regulations”

In addition to setting up a risk information window in the Operational Service Division to respond to various "risk of loss", Furthermore, we have secured the following special system.

• For disaster risk, by formulating a "crisis response management procedure manual" and introducing a safety confirmation system, We have a business continuity and recovery system in the event of a disaster.

Risk Countermeasure Office

At the Company, the Head of Operational Service Division will immediately set up the Risk Countermeasures Office in order to resolve, overcome or avoid the crisis as necessary, such as when a business crisis occurs or risk information may develop into a business crisis. We will convene and set up. The Risk Management Office will carry out the following operations.

• Collection of information on risks and management crises
• Contact with government agencies if necessary
• Study, decision and implementation of countermeasures
• Control of information inside and outside the company
• Examination, decision and implementation of recurrence prevention measures
• Other necessary measures

The Company stipulates that the Audit & Supervisory Board Members are required to attend the Management Meetings according to the "Audit & Supervisory Board Regulations". We have a system in place that allows us to request explanations and related materials and to conduct audits efficiently and effectively.
Furthermore, the Audit & Supervisory Board Members share information in cooperation with the internal audit department and accounting auditors, and strive to further enhance the effectiveness of Audit & Supervisory Board Audits by gaining a wide range of information on the current state of the Company.

In addition, in the "Risk Information Communication Regulations", we have established a system in which the Risk Countermeasures Office or employees directly report to the Audit & Supervisory Board Members regarding important information regarding matters that may cause significant damage to the company and compliance.

The Company has established "Rules for the exclusion of antisocial forces" and blocks all relationships with antisocial forces, In response to unreasonable demands by anti-social forces, we will endeavor to collect information and ensure safety in close cooperation with external specialized institutions such as lawyers and police, and to respond with a resolute attitude throughout the organization.

• Respect for human rights, prohibition of discrimination, sexual harassment, power harassment, etc.
  Respect human rights and do not engage in discrimination, sexual harassment, power harassment, etc. The victim clearly tells the other person, and others do not pretend to see it as a workplace problem.
• Security trade control
  To maintain international peace and security, we will implement strict security trade control, prevent legal violations, and do not engage in improper transactions as a company.
• Prohibition of bribery and gifts/entertainment
  Don't give, offer or promise improper profits. We do not assist other companies or participate in the conspiracy regarding these acts. Also, don't give gifts or entertainment to business partners beyond the scope that is socially reasonable.
• Prohibition of providing profits to antisocial forces
  We will take a resolute attitude toward antisocial activities and forces, and cut off any relationships.
• Inside trading regulation
  Do not violate insider trading regulations.
• Appropriate accounting processing, tax filing and proper disclosure of company information
  Accounting process and tax filing must be done properly. In addition, important company information must be disclosed appropriately.

We are promoting the following measures to prevent information security accidents.

Implementation of encryption and password protection for file transmission

We handle the collected personal information such as name, address, telephone/FAX number, E-mail address, company name, department name, and position according to the following policy.

1. Disclosure/change/deletion of registration information
   We will manage your personal information with the most accurate and up-to-date information possible. For disclosure/change/deletion of information, please request by the following procedure.
   
   (1)Download “Disclosure/Change/Deletion Request Form”.
   (2) Please fill in the required items on the request form.
   (3) Please send the resident's card enclosed and mail it to the address below.
   * The resident card will be returned when the reply is returned.
   
   Mailing address:
   Restar Building, 2-10-9 Konan, Minato-ku, Tokyo 108-0075 Japan
   PALTEK Co., Ltd.
   For personal information management
   
   * We will reply by mail within 1-2 weeks after receiving the request form.
2. Inquiries regarding personal information
   If you have any questions regarding our personal information protection, please contact us.