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 wide range of perspectives that all endeavors are predicated on thorough compliance, thereby raising awareness to compliance and enhancing measures against legal and regulatory 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 disseminated 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 2023. Group companies also have issued compliance manuals in line with their business affairs and forms of trading, and such activities foster and maintain a sense of compliance across the Group. In FY2022, 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 confirmed 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 on an individual basis. The Board of Directors supervises the status of compliance based on these reports.
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.
FY2022 Online Course on the Kajima Group Code of Conduct and Compliance
Attendance: 24,612 (including 10,464 attendees from 47 Group companies)
Attendance rate: 100%
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 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 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 classified information.
In FY2022, there were 23 whistleblowing cases.
Corporate Ethics Whistleblower System Framework
Strengthening the Implementation of the Bid-Rigging Prevention Framework
Kajima clarifies bidding processes for public works projects, mandates that decisions be recorded and stored 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 status of 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 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.
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" among 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 Policy" 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 unrelenting education by (i) making the "Kajima Group Anti-Bribery Principles" known to all employees, 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, gifts and entertainment whereby our directors, officers, and employees as receiving party.
Appropriate Expense Management
Regarding expenditures on and expense-sharing with public officials as well as private business partners, accounting and other departments scrutinize the recipient, usage, and purpose of expense in each case, and confirms legality and appropriateness considering applicable laws and regulations, guidelines, and rules published by the organization to which the recipient belongs. In addition, the Audit Department conducts periodic audits of the Accounting Department and other departments.
Restriction on Receiving Entertainment or Gift from Business Partners
Kajima establishes strict and clear rules for each type of behavior 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 Policy along with the other compliance and risk related matters are reported to and checked by the Compliance and Risk Management Committee when necessary. Results of deliberations at the Committee are reported periodically to the Board of Directors, whereas important matters are reported to them on an individual basis 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" as a condition for quotations and orders. In addition, the master 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, the Kajima Group and its supply chain partners cooperate and collaborate to promote thorough compliance with anti-corruption and other compliance requirements.
Initiatives to Prevent Corrupt Practices Including Bribery in Overseas Operations
As some of the countries and regions where the 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 against 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 templates for our contracts, and we check if a new business partner has any connections with antisocial groups when initiating business with it. 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.