Compliance
Ensuring Rigorous Compliance
Kajima has established the "Kajima Group Code of Conduct " as a base of compliance programs. In all aspects of our activities, it is necessary that all directors, officers, and employees to act in conformity with its corporate ethics. We inform directors, officers, and employees from a broad perspectives that all activities are founded on strict compliance, thereby raising awareness of compliance and strengthening measures against legal risks.
To encourage the understanding and spread of the Kajima Group Code of Conduct, we have issued the “Handbook for Practical Application of the Kajima Group Code of Conduct” as a compliance manual, and this is distributed to all directors, officers, and employees. We update the “Handbook for Practical Application of the Kajima Group Code of Conduct” as necessary after the scrutiny of effectiveness with reference to revision of laws and regulations as well as change in social conditions at the end of each fiscal year. The last revision was made in October 2025. Group companies also have issued compliance manuals tailored to their business operations and trading, practices, and such activities foster and maintain a sense of compliance across the Group. In FY2024, there were zero cases of severe legal violations.
To implement the compliance framework, cases concerning compliance and risks, along with disciplinary and whistleblowing cases, are reported and reviewed at the Compliance and Risk Management Committee as needed. Results of deliberations conducted by the Committee are reported periodically to the Board of Directors through the Committee, whereas important matters are reported individually. The Board of Directors supervises the status of compliance based on these reports.
The Handbook for Practical Application of the Kajima Group Code of Conduct
Attending an online course
Compliance System Framework
Spreading the Code of Conduct through an online course
To achieve further understanding and to spread the Kajima Group Code of Conduct, we have conducted an online course for all officers, employees, and temporary staff every year since FY2008.
FY2024 Online Course on the Kajima Group Code of Conduct and Compliance
Attendance: 25,710 (including 10,113 attendees from 47 Group companies)
Attendance rate: 100%
Whistleblower System
A whistleblower system (a corporate ethics hotline) has been established through which employees of Kajima, Group companies, partner companies, and others are able to report facts or suspicions concerning wrongdoing or legal violations in the Group. Anyone can report, anonymously if desired, misconduct or legal violations, including corruption such as bribery involving officers or employees. In order to ensure the ease-of-use and effectiveness of the system, multiple contact offices have also been established outside the Company.
This system prohibits retaliation and detrimental treatment against whistleblowers. We also promote awareness and encourage active use of the system by distributing awareness-raising cards and by other means.
External stakeholders can contact us at “Contact Office”. The details of notification and personal information are handled as confidential information.
In FY2024, there were 136 whistleblowing cases.
Leaflet for Group employees
Corporate Ethics Whistleblower System Framework
Strengthening the Implementation of the Bid-Rigging Prevention Framework
Kajima clarifies bidding processes for public works projects, mandates the recording and storage of decisions at each stage, and imposes certain restrictions on participating in external gatherings, thereby building a framework to prevent employees from being involved in illegal acts. In addition, to check the compliance with this framework on a regular basis, the Audit Department and Legal Departments at the Head Office conduct audits in cooperation with attorneys. Moreover, we hold Anti-Monopoly Act training sessions for sales representatives working at the Head Office and branch offices every fiscal year with attorneys serving as lecturers. In these training sessions, the “Manual for Compliance with the Anti-Monopoly Act,” which is distributed to all executive officers and employees, is used as a textbook and attendees receive instruction and training about specific points to note regarding compliance through case studies of incidents that may occur in daily sales activities.
Anti-Monopoly Act training session (Chubu Branch)
Manual for Compliance with the Anti-Monopoly Act
Prohibition of Corrupt Practices Including Bribery
Kajima includes "Fair, Transparent and Free Competition, and Appropriate Trade" and "Transparent Relations with Government" in the Kajima Group Code of Conduct. We also signed the United Nations Global Compact and support the principle that "Businesses should work against corruption in all its forms, including extortion and bribery" as outlined in the Global Compact's 10 Principles. Moreover, in order to further clarify our stance on anti-corruption and steadily promote our efforts therefor, both in Japan and overseas, we established the "Kajima Group Anti-Bribery Principles" in April 2021 after deliberation by the Board of Directors, and made it known to all officers and employees of the Kajima Group.
Initiatives to Prevent Corruption Including Bribery
Education and Training
The aforementioned "Online Course on the Kajima Group Code of Conduct" provides continuous education by (i) making the "Kajima Group Anti-Bribery Principles" known to all attendees, and (ii) incorporating points and questions with regard to rules of, not only, gifts to, bearing cost of, and sharing expenses with public officials (irrespective of domestic or foreign) and private business partners, but also handling gifts and entertainment received by our directors, officers, and employees.
Appropriate Expense Management
Regarding expenditures on and expense-sharing with public officials as well as private business partners, the Accounting and other related departments scrutinize the recipient, usage, and purpose of expense in each case, and confirm its legality and appropriateness considering applicable laws and regulations, guidelines, and rules published by the recipient’s organization. In addition, the Audit Department conducts periodic audits of the Accounting Department and other related departments.
Restriction on Receiving Entertainment or Gift from Business Partners
Kajima establishes strict and clear rules for each type of conduct which employees can take when working with business partners, including the prohibition of coercion against business partners and the restriction of receiving entertainment or gift that exceed social norms.
Supervision by the Board of Directors
The status of actions for anti-bribery and violations of the Anti-Bribery Principles along with other matters related to compliance and risk are reported to and checked by the Compliance and Risk Management Committee when necessary. Results of deliberations at the Committee are periodically reported to the Board of Directors, whereas important matters are individually reported to them via the Committee. The Board of Directors supervises the status of compliance based on these reports.
Cooperation with the Supply Chain
Before starting a transaction, Kajima screens nominated business partners based on our standards including compliance aspects, and requires business partners to act in accordance with the "Kajima Group Supply Chain Conduct Guidelines for Business Partners" as a condition for quotations and orders. In addition, the basic construction subcontract agreement, which we enter into before starting works with each business partner, requires them to comply with anti-corruption obligations and other policies established by Kajima. In this way, Kajima Group and its supply chain partners cooperate and collaborate to promote thorough compliance with anti-corruption and other compliance requirements.
Initiatives to Prevent Corruption Including Bribery in Overseas Operations
As some of the countries and regions where Kajima Group operates are considered to pose high risk for bribery, in April 2021, in accordance with the "Kajima Group Anti-Bribery Principles," Kajima established the "Kajima Corporation Anti-Bribery Policy for Foreign Public Officials, etc." in order to develop a more specialized management system in proportion to the level of risk. In addition, guidelines have been established for each type of conduct that is likely to cause problems (provision of benefits such as entertainment and gifts, donations and contributions, use of agents, etc.), setting forth specific procedures and criteria for judgment. While considering the actual situation in each country, we will continue to disseminate these rules and guidelines and further promote the prevention of bribery in our overseas operations.
Eliminating Antisocial Groups
Kajima has declared the eradication of antisocial activity within the Kajima Group Code of Conduct. In addition, we have established regulations against antisocial groups and compiled details about these regulations into a practical manual for addressing antisocial groups. All directors, officers, and employees are working to eliminate antisocial groups according to top-executives’ strong determination and guidance. Specifically, we have defined an internal structure to take action against antisocial groups and we have established coordination with external specialized agencies, including police. In addition, we have included clauses regarding the exclusion of organized crime groups in our contract templates, and we check whether new business partners have any connections with antisocial groups before initiating business with them. If we find out that a new business partner is an antisocial group, we conduct Company-wide efforts to terminate all contracts with that group promptly.
Furthermore, we strengthen coordination on a daily basis between the Head Office and branch offices, and we hold Head Office meetings for persons in charge of administration at branch offices and training sessions in cooperation with police and other organizations, thereby sharing information and ensuring consistent awareness to compliance.
A signboard calling for the exclusion of organized crime groups that is put up at all construction sites since FY2010
