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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 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 2020. 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 FY2020, 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.

The Handbook for Practical Application of the Kajima Group Code of Conduct

The Handbook for Practical Application of the Kajima Group Code of Conduct

Attending an online course

Attending an online course

Compliance System Framework

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.

FY2020 Online Course on the Kajima Group Code of Conduct

Attendance: 22,652 (including 9,210 attendees from 38 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 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 FY2020, there were 23 whistleblowing cases.

Leaflet for Group employees

Leaflet for Group employees

Corporate Ethics Whistleblower System Framework

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.

Anti-Monopoly Act training session (Chubu Branch)

Anti-Monopoly Act training session (Chubu Branch)

Manual for Compliance with the Anti-Monopoly Act

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 in March 2019 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. In April 2021, we established the Kajima Group Anti-Bribery Principles to continue steadily promoting of anti-corruption initiatives in Japan and abroad.

Initiatives to Prevent Corruption including Bribery

In terms of initiatives to prevent corruption, Kajima promotes the Kajima Group Code of Conduct, conducts education, training, and audits and disseminates and practices the recently formulated Kajima Group Anti-Bribery Principles.

Education and Training

Kajima makes it a rule to include items and questions concerning the prevention of corruption including bribery in the online Kajima Group Code of Conduct course provided annually to all officers, employees, and temporary staff, including those of domestic Group companies, for the sake of unrelenting education.

Appropriate Expense Management

The Accounting and other departments rigorously check the recipients and purpose of payments and expenses to confirm legality and propriety. In addition, the Audit Department audits the Accounting and other departments periodically.

Supervision by the Board of Directors

Violations of the Anti-Bribery Policy along with 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.

Raising Awareness throughout the Supply Chain

Kajima disseminates and promotes the Kajima Group Conduct Guidelines for Business Partners and this Policy throughout the supply chain. The Kajima Group promotes compliance, including the prevention of bribery and other corrupt practices, in cooperation and coordination with its supply chain.

Initiatives to Prevent Corrupt Practices including Bribery in Overseas Operations

In addition to the Kajima Group Anti-Bribery Principles, the Kajima Corporation Anti-Bribery Policy for Foreign Public Officials, etc. and the Guide to the Provision of Benefits to Foreign Officials as Entertainment, Gifts, etc. have been formulated to define a management framework to prevent the bribery of foreign public officials, as well as rules and initiatives for directors, officers and employees to observe. Going forward, we will disseminate and promote the policy and guidelines while taking into account the conditions in each country, thereby furthering anti-bribery in our overseas operations more effectively. In addition, departments supervising overseas operation promote initiatives such as conducting training sessions led by attorneys.

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.

A signboard calling for the exclusion of organized crime groups that is put up at all construction sites since FY2010

A signboard calling for the exclusion of organized crime groups that is put up at all construction sites since FY2010

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