Chiyoda has established the chief officer system as of April 1, 2018 and the board of directors appointed the Chief Compliance Officer (CCO) in charge of everything related to compliance by Chiyoda Corporation and Chiyoda Group companies.
The Division Director and the Operations Director are to serve as the Compliance officer (CO) on their own divisions and are responsible for implementing measures and policies related to compliance in his or her division under the supervision of the CCO.
The president of a Group company or his or her proxy is to serve as the Group Company Compliance Officer of the company. The Group Company Compliance Officer is responsible for implementing measures and policies related to compliance under the supervision of the CO of the governing division.
We have continuously conducted the training programs such as seminars by outside professional instructors and online courses by e-learning for all the employees including our group companies. With the increase in global compliance risks, such as bribery for foreign government officials, human rights issues and the like, employees taking up new overseas assignments are given pre-assignment training with an emphasis on the risks associated with overseas assignments. Further, we have conducted the activities to raise awareness of the Chiyoda Group’s Code of Conduct and relevant compliance rules among such members as in our overseas group companies and joint venture partners.
The Chiyoda Group conduct “Risk Assessment” every fiscal year in order to identify the risks which we have to deal with preferentially. We select such risks by plotting all risks according to the frequency of occurrence, the degrees of damages and present measures. We implement the countermeasures specific to such risks.
Implementation of Preventive Measures
The Chiyoda Group implement the following preventive measures / procedures , among other things, particularly for high risk items: ･Due Diligence relating to compliance on business partners of our supply chain including vendors, subcontractors, agents, consultants prior to forming the tie-up ･ Prior confirmation procedures for governmental officials, OFAC, biddings, payments for entertainment fees, etc.
As part of our mechanism for ensuring compliance of Chiyoda Group Code of Conduct, we have also implemented monitoring periodically, and made improvements if required. The monitoring includes “the Construction Industry Law”, “the Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors”, to prevent bribes to officials, and “the Anti-Trust Law” (to prevent bid rigging), etc.
All divisions in CGH and group companies conduct “self-assessment”, and they monitor their activities as for Compliance themselves.
The Legal & Compliance Department in charge of promoting compliance monitor the compliance activities in Chiyoda Group including all divisions and group activities and review the compliance program for the next fiscal year.
Besides the Legal & Compliance Department, the Internal Audit Department as an independent organization also conducts auditing activities.