This Code of BELLSYSTEM24 Group Conduct (hereinafter referred to as the "Code") sets forth the basic standards of conduct to be voluntarily observed by each of all officers and employees of BELLSYSTEM24 Group (each group company shall be hereinafter collectively or individually referred to as the "Company") (hereinafter referred to as the "Officer and Employee").
The Company complies with all applicable laws, regulations and rules of the countries and regions in which it conducts business activities, respects international rules such as protection of human rights and the local culture and customs of such countries and regions, and acts with common sense and responsibility as a member of the international society.
The Officer and Employee shall make decisions for business activities in order that the decisions may be in the best interest of the Company.Decisions for business activities shall be made with the following preconditions: lawfulness and legitimacy based on the objective facts from a viewpoint of fairness and equality; disinterest; within the scope of the authority and no deviation from its discretion; due care; and appropriate review. The Company establishes an environment necessary for each Officer and Employee to make appropriate decisions in accordance with such preconditions.
The Company will strive to earn customers satisfaction and trust through the provision of socially useful and creative services, while giving consideration to the quality, reliability and information security of the service to be provided.
The Company accurately grasps and responds to the diversified, complex and sophisticated needs of customers from the perspective of the customers. In addition, the Company will, with its accumulated know-how and experience, always strive to create new value and solve problems for customers.
The Company helps customers make their selection on a voluntary basis through enlightenment activities, such as seminars and lectures, and establishes relations of trust with customers through such communication.
The Company promptly responds to inquiries and the like from customers in good faith and reflects the voice of customers in the service and, where necessary, promptly improves the service, or implements measures to prevent recurrence by conducting a thorough investigation into the cause, which lead to the improvement of the quality and the development of new services.
Based on the recognition that fair, transparent and free competition is essential for the sound development of the social economy as well as the Company, the Company complies with the competition laws of the countries and regions in which it conducts business activities.
The Company never performs any act that may impede fair, transparent and free competition, which includes: unfair restraint of trade, such as cartels to fix the price and contents of the service, and the area for which the service is provided, and the like, and bid rigging to decide the winning company and set the winning price in the public bid; and unfair business practices such as abuse of a superior bargaining position, which unduly imposes a disadvantage on the conditions and implementation of business transaction.
In order to ensure the soundness of its business activities, regardless of whether it is prohibited by the law or not, the Company never gives or receives entertainment, payment, gifts and any other benefits beyond the socially acceptable extent to or from customers, suppliers or other business partners.
With respect to its services to be provided, the Company never engages in false, inaccurate or misleading advertising, or other description, and never engages in advertising that may slander others. In addition, the Company never performs any act of unfair competition, such as false, inaccurate or misleading presentation and provision of excessive gifts and the like.
Based on the recognition that the cooperation and support of suppliers is essential in its business activities, the Company will strive to maintain and establish long-term trust relationships with the suppliers.The Officer and Employee who engage in transactions with suppliers shall take a fair and impartial attitude to such suppliers or potential suppliers for procurement, and never receive any personal profit, such as entertainment, gifts or gratuities, beyond the socially acceptable extent from such suppliers.The Company never performs any act, such as beating down of prices, refusal of receipt, return of goods or delay in payment, which is prohibited by the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, or any act that may impose an unfair burden on suppliers by abusing its dominant bargaining position.When selecting suppliers, the Company performs detailed evaluation of the suppliers' approach to the social responsibility, such as compliance with laws and regulations, respect for human rights, information security, and environmental protection, as well as the prices of goods and services, quality, reliability, and delivery date that are provided by the suppliers.
When entering into a contract, the Company confirms the terms and conditions of the contract in writing form and the like, and then accurately evaluates the risks and costs and, where necessary, performs a risk assessment with the cooperation of experts, and concludes the contract in a proper and clear manner.
The Company shall maintain sound, normal and fair relationships with the government and public administrations, and never performs any act, such as provision of benefits (including illegal political contributions, entertainment, gifts and payments) or any other act that may incur such suspicion.Regardless of whether it is prohibited by the law or not, the Company never performs any act, such as provision of benefits (including illegal political contributions, entertainment, gifts and payments) to public officers (including officers of local governments and public institutions) of any country and region, or any other act that may incur such suspicion.
Amid the increased risk of leakage of information owned by companies with the development of the information society, the Company once again recognizes the importance of confidential information, including personal information, customers' information and insider information, and strengthens its information security management in order to strictly protect the confidential information.The Company shall use the confidential information only for legitimate purposes and never discloses such information, beyond the necessary extent, to the Officer and Employee as well as a third party.The Company continues to provide opportunities for the Officer and Employee to acquire a high level of knowledge and discernment regarding the handling of confidential information, which includes implementation of periodic educational programs on information security.
The Company strictly handles information containing the personal privacy of individuals (including customers, suppliers, and the Officer and Employee) and never discloses such information to a third party without justifiable reasons and the prior consent of the relevant person.
The Company properly protects not only its own information managed by the Company as confidential, but also the confidential information of other companies that was entrusted or provided to the Company.The Company obtains confidential information of other companies through fair and proper means, including conclusion of a confidentiality agreement, but never obtains such information through unfair means. In addition, if the Company knows that the information was obtained through unfair means, the Company never acquires, uses or discloses such information.The Company shall properly manage confidential information depending on the importance level thereof. When disclosing confidential information of the Company, the Company takes adequate protection measures, such as conclusion of a confidentiality agreement, prior to the disclosure.
Based on the recognition that the protection of intellectual property rights is essential to ensure fair competition, the Company properly protects the intellectual property rights (including patents, trademarks and copyrights) owned by the Company. In addition, based on the recognition that the original brand of the Company is an important management resource, the Company will strive to maintain and further improve the value.
The Company respects the intellectual property rights of a third party and never performs any act, such as illegal use or violation of such rights. In addition, the Company always pays attention not to violate the intellectual property rights of a third party in the process of provision of its services or in the performance of its business activities, and will endeavor to make an appropriate response if there is a risk of a violation of the intellectual property rights of a third party.
The Company, in accordance with the applicable laws and regulations, performs fair accounting processing, and records and reports appropriate information. The Company prepares these records and reports, which should be accurate and clear and easy to understand, based on the facts on a timely basis, and never conducts any act that may cause falsification and misunderstanding, which may lead to illegal processing or inappropriate recording.
Based on the recognition that companies assume social responsibility for stakeholders (including shareholders, customers, suppliers, employees, local communities and public administrations) and it is important to perform its accountability obligation in order to execute such responsibility, the Company will, regardless of the scope of the law, endeavor to promote dialogue with stakeholders through active and fair disclosure of information.The disclosure of information should be conducted appropriately and on a timely basis, and the information should be easy to understand.Based on the recognition of the responsibility for the influence of its business activities on society, the Company operates business activities in harmony with the society by respecting the needs of stakeholders to the extent possible.
In consideration of the fact that global environmental protection is a common concern of all mankind, and based on the recognition that approaching such challenge is an essential condition for a company's existence and operations, the Company will voluntarily and independently strive not only to cooperate in the implementation of the measures on environmental protection that are formulated by national governments, etc. but also to contribute towards building a sustainable society.In the process of provision of services and in the performance of business activities, the Company will, in consideration of its effect on the environment, strive to reduce such impact on the environment to the extent possible through the use of energy-efficient equipment, reduction and segregation of waste, and the like, and to actively use products and services that make full use of recycled resources.
In order to fulfill its social responsibility, the Company recognizes that it is requirements from stakeholders to directly or indirectly address tasks and issues faced by the society, and not only provides socially useful services but also actively fulfills its responsibility as a member of the society by creating and promoting employment opportunities, contributing to the local economy, and the like.
The Company uncompromisingly confronts antisocial forces and groups, including organized crime groups, which threaten the order and safety of civil society, and never has any relationship, including business relationship, with such forces and groups.Before entering into business relations, the Company pays attention to whether the other party belongs to antisocial forces or groups or not, and if such forces or groups seek a business relationship or make unreasonable demands, the Company definitely rejects such demands in a resolute attitude.
In response to the globalization of business, the Company operates in consideration of the various interests of stakeholders and social issues in the countries and regions in which it develops business activities, and will strive to build a trust relationship and also contribute to the development of the countries and regions.
Based on the recognition that human resources are important management resources, the Company respects the diversity, personality and individuality of the employees and will strive to provide them with a comfortable work environment in which they can work with a sense of security and feel job satisfaction.
The Company will strive to ensure the safety and health of employees in accordance with the applicable laws and regulations, including the Labor Standards Act and the Industrial Safety and Health Act.
The Company never employs children aged under the legal minimum age for labor stipulated by the laws of the countries and regions in which it operates, or never forces anyone to work against his or her will.
The Company will strive to create a bright and open workplace where talented, motivated and diverse personnel can work actively without discrimination based on sex, age, national origin, race, religion, existence or absence of handicaps, etc. and unfair treatment regarding recruiting, employment, promotion, etc.
The Company shall objectively evaluate employees' abilities based on the fair evaluation system, and supports human resources development and career development by placing the right person on the right job, while respecting aptitudes and individual initiatives of employees.
The Officer and Employee shall respect others' human rights and never perform any act, such as sexual language (sexual harassment) or harassment by a senior person who takes advantage of his or her position (power harassment), which may impair others' dignity, disturb public order and morals of the workplace, and prevent the performance of business activities.
In order for employees to gain job satisfaction and realize an affluent and comfortable life, the Company supports to balance work and family by implementing measures, such as reducing overtime working hours and encouraging taking off annual paid holidays, and promotes a better work-life balance for employees.
Based on the recognition that the Officer and Employee assume a duty to protect the assets leased from the Company from loss, damage, theft, etc., they comply with the rules set forth by the Company regarding the management thereof paying attention to prevent such from happening.
The Officer and Employee use the tangible and intangible assets leased from the Company only for the legitimate business purposes and never use them for any private or unlawful purposes.
The Officer and Employee never perform any act that results in or may result in a conflict of interest between the Company and themselves or a party who has a relationship with themselves, which includes engaging in any business that competes against the Company's business or assuming the position of officer of the company whose business competes against the Company's business. In addition, the Officer and Employee never be engaged in business and never assume the position of officer or employee of the other company or organization without the prior permission of the Company.
The Officer and Employee never obtain material information about the Company or its business partners, except in the case where it is needed for its business activities.When obtaining material information about the Company or its business partners for the necessity for its business activities, until the information is made public, the Officer and Employee never trade stocks, etc. nor disclose the information to anyone except for the Officer and Employee who are deemed to need the information for its business activities.
Response to the media shall be made in accordance with the instructions of the public relations division. The Officer and Employee never contact the media without the approval of the public relations division and never make a statement on behalf of the company or a statement that may be deemed to be made on behalf of the Company.When making any statement about the matters related to the Company (including comments made using various social networking tools) even during their personal time and in their personal space, the Officer and Employee pay due attention, have the sense of responsibility and awareness, disclose the identity, and clearly indicate that the content is based on its personal opinion but not the opinion or position on behalf of the Company. In addition, in the statement, the Officer and Employee never mention information not made public, including confidential information about the Company and its business partners, and never mention the business partners.
The top management, based on the recognition that its task is to ensure thorough compliance of the Code, takes the initiative to realize this and establishes a code of corporate ethics through the improvement of the ethical standards of the Officer and Employee.
The top management establishes a companywide system for managing the compliance with the Code, constantly listens to the voices of people both inside and outside of the company, and exercises its leadership necessary for the system to be effective and function effectively.
In order to fully disseminate the Code, the top management implements educational and training programs, confirms the degree of penetration and establishment periodically, and maintains and improves the ethical standards of the Officer and Employee. In addition, the top management disseminates the approach toward compliance with the Code to suppliers, endeavors to obtain necessary cooperation of suppliers to comply with the Code, and thoroughly promotes awareness of corporate ethics among employees of suppliers.
In the event of a violation of the Code, the top management clearly demonstrates its commitment to solve the problem and, under its direction, promptly confirms the facts and thoroughly investigates the cause, and takes necessary measures to prevent recurrence.In addition, the top management clarifies the responsibility and severely punishes those involved, including itself.In case that any act in violation of the Code or any act that may be in violation of the Code has been found, the top management sets up a whistle-blower hotline (Corporate Ethics Hotline) that is independent from the ordinary chain of command and creates an environment in which employees can safely and promptly report and consult on such act. With respect to the employees who reported the act or cooperated with the investigation, the Company, with due consideration for anonymity, treats them in a fair and proper manner but never treats them in a disadvantageous manner.
With respect to the violation of the Code, the Company, in accordance with the provisions of the reward and punishment rules, severely punishes those involved, including officers or employees who assume supervisory responsibility for the person who violated the Code.
