Applying the Group Code of Conduct, a variety of initiatives are conducted in the SEGA SAMMY Group to keep all employees aware of compliance issues so that we can act accordingly.
Furthermore, having identified loss risks within and outside the scope of its business management and clarified the tasks it should address, the Group implements operations, minimizes the loss of management resources, and prevents recurrence.

To improve awareness and foster understanding related to compliance, the SEGA SAMMY Group carries out training seminars, e-learning and various other awareness-building activities as appropriate that target all group officers and employees. It also works to improve compliance awareness by making related information continuously available. This includes sending out e-mail newsletters alerting officers and employees to compliance risks based on scandals in society, as well as using the intranet to make available such things as the group’s compliance handbook and explanatory information following changes to laws.

The Group has established a whistleblower system to enable selfcorrection within the Group and to prevent scandals due to illegal or unfair practices. The Group investigates reported matters, rectifies them, and takes measures to prevent recurrence of such issues. Also, the Group has established a system that protects whistleblowers and uses its intranet and posters to inform all employees about the system.
In 2019, the Group was registered as a registered business under the “Whistleblowing Compliance Management System (self-declaration system)” governed by Japan’s Consumer Affairs Agency, and is making efforts to properly maintain and operate its whistleblowing system.

We have established internal regulations to prevent insider trading by employees and officers. These rules describe legal restrictions on stock trading, and require all officers or employees to report planned purchases or sales of the Company’s shares.
We have taken steps to raise officer and employee awareness of key issues, disseminating information on insider trading regulations through our intranet.

The SEGA SAMMY Group has the Group CFO serving as the chief officer responsible for tax matters, and the tax department at SEGA SAMMY HOLDINGS oversees tax-related issues in cooperation with Group Companies and relevant departments.
From the perspective of enhancing management transparency, we conduct tax reporting and payment appropriately by understanding and staying up to date with the latest tax-related laws and systems in each country and region.
We also promote tax compliance awareness by disseminating tax-related information to Group Companies and relevant departments.
We believe that managing taxes in an appropriate and transparent manner and making proper tax payments in accordance with the tax systems of each country and region, are important responsibilities that contribute to society.

(Approach to Tax Risk)
To identify and minimize tax risks at an early stage, we collaborate with the tax department at SEGA SAMMY HOLDINGS, Group Companies, and relevant departments to collect relevant information.
When tax risks are identified, we seek advice from external experts as necessary and take prompt action.

(Approach to Tax Planning)
We believe that transactions conducted without legitimate business purposes or economic rationality hinder tax transparency, undermine stakeholder trust, and  potentially reduce our corporate value.
Therefore, we do not engage in tax planning that deviates from the intent of laws and regulations, nor do we use tax havens for the primary purpose of tax avoidance.
At the same time, from the perspective of maximizing cash flow, we utilize preferential tax systems and tax treaties stipulated by the tax laws and regulations of each country and region to ensure appropriate tax payments without overpayment or underpayment.

(Approach to International Taxation)
We comply with transfer pricing regulations and BEPS guidelines established by the OECD as well as by each country and region, strive to ensure fair profit allocation among countries in accordance with the functions, risks, and assets of overseas Group Companies, and endeavor to conduct appropriate cross-border transactions.

(Relationship with Tax Authorities)
We endeavor to build trust and maintain constructive relationships with tax authorities in each country and region by providing timely and appropriate tax information and making advance ruling when necessary.
In addition, we aim to engage in constructive communication during tax audits and, implement preventive measures for any issues identified for improvement, , in cooperation with Group Companies and relevant departments.

To prevent corruption (such as unlawful payoffs, favors, or gifts) and ensure appropriate donations for social contribution as identified in the Code of Conduct, the SEGA SAMMY Group strives to make it clear that fairness is required. Compliance with company rules, established in line with relevant regulations, is mandatory.

The Company, SEGA, and Sammy have established business continuity plans to maintain or quickly restore operations after natural disasters or accidents. Safety verification systems enable prompt, reliable confirmation of local conditions and the safety of employees or their family members in emergencies. Emergency communication protocols and equipment are in place, and we are investigating groupwide deployment.

In today’s rapidly advancing information society, where highly networked information technology (IT) increasingly impacts corporate value, ensuring IT security and protecting information assets from various threats is not only a critical management issue but also a social responsibility for companies.

The SEGA SAMMY Group continuously implements measures and improves standards based on this policy, aiming to be a company that is consistently trusted by all stakeholders, including our customers.

We provide the necessary training to ensure and maintain IT security.

Every year, we provide information literacy education and training (E-learning) to all employees of the SEGA SAMMY Group. In addition, we conduct targeted email attack training and quick training sessions on notable cases multiple times a year.

We conduct information security audits and internal inspections to verify that the SEGA SAMMY Group’s information security measures are appropriately maintained and managed. Information security audits are conducted in the form of either internal or external audits. Based on the results of these information security audits and internal inspections, we improve and revise our information security measures.

At the SEGA SAMMY Group, we adopt a “multi-layered defence” approach as our countermeasure against cyber attacks, enhancing information security by integrating multiple protection and detection mechanisms to address both external and internal threats.

We conduct vulnerability assessments on publicly accessible servers related to the products and services provided by the SEGA SAMMY Group. Based on the results of these assessments, we also implement corrective actions and countermeasures, and share the findings through the Information Security Committee when necessary.

To ensure the safe and secure use of cloud services within the SEGA SAMMY Group, we have implemented a system where the department intending to use the service submits usage requests, which are then reviewed and approved by the Information Security Department. Furthermore, depending on the nature of the business and outsourced operations, we conduct inspections of information security measures on external contractors and issue warnings or requests for corrective actions when necessary.

Intellectual property is treated as an important means to enhance Group competitiveness and is positioned as a significant management resource. Group companies each uphold their own, individualized policies. Sharing of information among Group companies is encouraged, and at the same time, the Group complies with rules and regulations that govern competition and intellectual property rights.