Code of Conduct

Management Policy

SEGA SAMMY Group Management Policy

As part of the fundamental development of our group-wide compliance system, we, the SEGA SAMMY Group, have established this “SEGA SAMMY Group Management Policy,” which provides more detailed descriptions of the SEGA SAMMY Group Code of Conduct and specifies the minimum matters to be observed.
The applicable scope of this policy is the same as that of the SEGA SAMMY Group Code of Conduct.

The SEGA SAMMY Group will establish internal rules and other regulations that exceed the standards specified in this policy, or make arrangement to apply this policy after having made changes as appropriate, and promote the execution thereof.

SEGA SAMMY Group Human Resources Policy

Basic Philosophy

We, the SEGA SAMMY Group believes that the creativity and adventurous spirit of our employees are the foundation of our growth, and that employees are our most valuable assets. We aim to create an environment where employees can enhance their own value and work energetically with a sense of pride and satisfaction.

Basic Policy

(Compliance with Laws and Regulations)

We comply with labor-related laws, including minimum wage, overtime, statutory benefits, and working hours. Based on fair evaluations, we provide appropriate compensation in return.

(Realization of a Harmonious Working Environment)

We respect individuality and embrace challenges, fostering a corporate culture where employee think independently and showcase their abilities and creativity; enabling them to reach their full potential.
We provide flexible work options which allow employees to enjoy a healthy work-life balance, while promoting a vibrant and diverse corporate culture.
We do not allow discrimination (Note 1) in job offerings and employment and strive to ensure equal opportunities and fair treatment for all.
We provide a safe and comfortable working environment.
We respect the human rights of our employees and strictly prohibit any harsh or inhumane treatment, including abuse, corporal punishment, sexual harassment, and power harassment (verbal abuse, intimidation, or coercive behavior).

(Others)

We respect our employees’ right to organize for labor-management consultation.
We employ all our employees of their own free will and do not impose any forced labor through means such as assault, intimidation, confinement or other measures that unfairly restrict mental or physical freedom.
We do not employ any children under the minimum working age. In addition, we do not allow any work that hinders their development.

(Note 1) Discrimination refers to providing different opportunities and/or treatment with regard to recruitment, promotion, remuneration, training, enrollment in training sessions, etc., based on factors other than reasonable considerations such as an employee’s abilities, aptitude and performance. Discriminatory factors include, but are not limited to, race, creed, gender, age, social status, family origin, nationality, ethnicity, religion, regional origin, skin color and sexual orientation.

SEGA SAMMY Group Occupational Health and Safety Policy

Basic Concept

Based on the concept that “the protection of health and safety is our utmost priority,” we, the SEGA SAMMY Group, act in compliance with relevant laws and regulations as well as with the voluntary management standards of each company and make efforts, as a group, to create a secure, healthy and safe work environment which is prepared to deal with potential accidents/disasters.

Basic Policy

(Health and Safety)

We will evaluate the risks concerning workplace security and ensure safety with appropriate designs and technology/management tools.
We will take appropriate security measures for any machinery and equipment, etc., that we use.
We will recognize the situations where any employee may come into contact with any chemical substance, noise or offensive odor that is harmful to the human body and take appropriate measures in response thereto.
We will recognize the situations surrounding industrial accidents and work-related illnesses and take appropriate measures in response thereto.
We will implement appropriate health management for all employees.
We will appropriately ensure the health and safety situation of the facilities provided for the benefit of employees (e.g., the cafeteria and restrooms).

(Disaster Prevention)

We will hypothesize which accidents, disasters, etc., may arise, prepare countermeasures in the case of an emergency and keep everyone in the workplace informed of the same in order to protect the safety of life and limb.
We will identify work that causes a heavy burden on the body and appropriately manage such work so as to prevent disaster/illness.

SEGA SAMMY Group Risk Management Policy

Basic Concept

The business environment surrounding us, the SEGA SAMMY Group, is rapidly changing and the risks associated therewith are complicated and wide-ranging. We consider that it is imperative for the continuation of our business that we not only respond to crises (emergency situations), but also that we grasp potential significant risks both within and outside of our operations.
In times of peace we will consider measures to prepare against potential material risks that may prevent us from maintaining or improving the promotion of our business and corporate values and we will construct systems that minimize potential losses, thereby putting forward our best efforts to minimize any effects on the various stakeholders involved and aiming to become a company that gains a strong level of trust from society.

Basic Policy

Through the practice of risk management, we will promote the continuous and stable development of our business and seek to safeguard our corporate assets.
We will place the utmost priority on the safety of human lives at times of emergency, and, in accordance with the “SEGA SAMMY Group Crisis Management Guidelines,” will put forward our best efforts to achieve a prompt recovery and minimize any hindrance to our business activities.
We will promote the spreading of risk awareness and the fostering of risk sensitivity by way of awareness-building activities such as education and training and by sharing risk-related information.
We will strive to prevent the reoccurrence of any crisis.

SEGA SAMMY Group Information Management Policy

Basic Concept

We recognize that, in the current advanced-information age, appropriately managing trade secrets and other information (“Confidential Information”), will provide protection for our corporate assets and will lead to the strengthening of our business, while at the same time considering it to be the social responsibility as a company.

The SEGA SAMMY Group will comply with relevant laws, regulations, and other norms concerning the management of Confidential Information and will appropriately manage and protect any information, including Confidential Information, received from customers and third parties.

We will keep each employee thoroughly informed of the following “Information Management Policy”, as well as the separately stipulated “IT Security Policy” and “Privacy Protection Policy.”

Basic Policy

We have established internal regulations, etc., and will strive to strictly comply with relevant laws and regulations, etc.
In addition, we will provide constant training about the management of Confidential Information and take strict measures against violators.
In order to prevent accidents such as loss, destruction, falsification, leakage of information, we will strive to achieve appropriate information management, such as restriction of access to information and management of information, countermeasures against unauthorized access and computer viruses and having a clear desk policy in the office.
We will identify each and every item of Confidential Information according to the applicable area and characteristics thereof and strive to achieve appropriate handling of Confidential Information according to the level of confidentiality.
In addition, we will strive to grasp the management status of Confidential Information on a periodic basis and will take necessary measures if any problem arises, etc.
We clearly specify our confidentiality obligations in our work rules and various regulations and also clarify the confidentiality obligations which are to be assumed by our employees.

（1）Employees are required to strictly manage the company’s Confidential Information and will not disclose and leak the company’s Confidential Information without taking the applicable procedures under our internal regulations etc., not only during their time of employment but also after resignation.

（2）Employees will not wrongfully or unjustly use the company’s Confidential Information, not only during their time of employment but also after resignation.

（3）Employees will not use any Confidential Information such as customers, suppliers, sales partners and other business partners, that they come to know in their business activities for any purpose other than a legitimate purpose and will manage such information in accordance with our internal regulations etc., to prevent the disclosure or leakage.

（4）Employees will not access or obtain any Confidential Information from customers, suppliers, sales partners, other business partners and/or competitors by way of wrongful means.
If, by any chance, any leakage of Confidential Information, etc., or any security-related problem occurs, we will investigate the cause and take appropriate measures to prevent reoccurrence, such as promptly contacting related divisions or disclosing necessary information.

SEGA SAMMY Group IT Security Policy

Basic Concept

Given the fact that the rapid progress of the information age, such as through highly-networked information technology (IT), is currently having an increasing influence on corporate value, the SEGA SAMMY Group consider that ensuring IT security and protecting information assets from various threats are important business challenges and that they also comprise the social responsibility of the company.

The SEGA SAMMY Group will constantly practice the countermeasures based on this policy, improve the level thereof and aim to become a company that is always trusted by customers and other various stakeholders.

Basic Policy

(Compliance with Laws and Regulations)

We will comply with relevant laws, regulations and other social norms concerning IT security.

(Establishment of Systems)

Based on this IT security policy, we will determine the roles of persons in accordance with the duties they are engaged in and establish a system which IT security can be promoted with on SEGA SAMMY Group.
We will establish and conduct basic regulation (“Global Information Security Policy”) that stipulate the basic requirements under this policy and management standard of specific compliance and criteria for judgment (“Global Information Security Standard”).
We will implement appropriate human resource, physical and technical measures and strive to prevent the occurrences such as unauthorized intrusion, information leakage, falsification, loss, theft, destruction, or obstruction of usage, in respect of information assets.
The management personnel who administer IT security will secure human resources who have the essential abilities to secure and maintain the IT security and appropriately assign such human resources.
The management personnel who administer IT security will understand “Global Information Security Policy” “Global Information Security Standard” or the guidance procedure, which are separately establish, and the situation of IT security and report them regularly to the Board of Directors to improve.
In order to secure stable IT operations, we will regularly strive, to reduce risks and prevent any potential crisis.

(Response at the Time of Accidents)

If, by any chance, any security-related problem occurs or is likely to occur with regard to any information assets, we will promptly investigate the cause and make efforts to minimize any damage caused thereby.

(Education)

We will provide essential education to secure and maintain IT security.

(Enhancement of Outsourcing Companies’ Management System)

Upon the execution of any outsourcing agreement, the SEGA SAMMY Group will require the outsourcing company to maintain security levels that are equivalent or superior to those of our group and will thoroughly examine the eligibility of the outsourcing company.

(Others)

If any employee breaches this IT security policy on purpose or gross negligence, the employee will be subject to punishment, in accordance with the Work Rules etc.”

SEGA SAMMY Group Privacy Protection Policy

Basic Concept

The SEGA SAMMY Group recognizes that privacy is a fundamental human right that should be fully respected and is essential for individuals to live safe and secure lives. We consider the protection of personal information as a critical management issue to be addressed as part of risk management in our business activities, within the broader context of privacy protection.　The SEGA SAMMY Group fully recognizes the importance of the privacy and personal information of our customers, business partners and employees (including contract employees, temporary workers, etc.) that we use in our business operations and considers that it is our social responsibility to appropriately conduct safe and secure management of such personal information.

We will conduct appropriate management of personal information (i.e. in the acquisition, use and provision) in accordance with internal regulations, etc., and, at the same time, take necessary and appropriate security measures and strive to protect privacy and prevent the information leakage etc.

Basic Policy

We will establish a framework to promote privacy protection and raising awareness of privacy.
With regard to the handling of personal information, we will comply with the Act on the Protection of Personal Information and other norms.
We will provide appropriate explanations on our purpose of using personal information to the owner of such personal information (who is the subject of the same) and will only use such personal information to the extent that his/her consent is obtained and within the scope of such purpose of use. In addition, we will not provide or disclose any personal information we hold to any third party without the consent of the owner of such personal information except of relevant laws and regulations, etc.
If an owner of the personal information we hold makes requests such as disclosure, correction, deletion, etc., of his/her personal information, we will respond appropriately in accordance with relevant laws and regulations.
We will make efforts to maintain the personal information accurately and up-to-date we hold and, at the same time, ensure the security to prevent potential accidents such as unauthorized access or leakage of personal information.
In addition, when we outsource the handling of personal information to an outside company, we will take necessary measures to ensure that the outsourcing company manages personal information at an equivalent level to our management of personal information.
We will constantly provide employees with training about handling of privacy and personal information.
If, by any chance, an accident such as the loss and leakage of privacy and personal information occurs in relation to the handling of personal information, we will promptly implement appropriate measures, including conducting an immediate investigation into the cause and implementing countermeasures to prevent the reoccurrence.
We will regularly review our handling of privacy and personal information and strive to achieve the continuous improvement.

SEGA SAMMY Group Sustainability Policy

Basic Concept

(Our Future Vision through Sustainability)

The SEGA SAMMY Group (the group) has established our mission, “Constantly Creating, Forever Captivating -Making Life More Colorful-,” .and we believe every employee takes pride in his/her work and will come to realize that they contribute to the sustainable development of society, by continuously providing “moving experiences” to people all around the world. By promoting sustainability management, we aim to become a corporate group that is trusted, needed and respected by society. We will also comply with international rules and laws and conduct business in a fair and sincere manner.

Basic Policy

(Setting Priority Themes to Be Addressed)

With the mission and purpose of “Constantly Creating, Forever Captivating,” we to meet the needs of society, realize a sustainable society, and enhance corporate value. To achieve this, we focus on the value created by our main businesses, set up materialities linked to our businesses, and work to permeate and put them into practice throughout the group.
In addition, in order to achieve coexistence with multiple stakeholders, we will regularly confirm important issues that we should address by promoting cooperation in each activity and confirming opinions and requests for group through dialogue.

(Release of Information to the Public and Promotion of Awareness within the Group)

We have established sustainability policy and release them to the public on our website and through other media. In addition, we raise awareness and promote understanding about the policies and the outline of our activities among the officers and employees in the group through training sessions, distribution by company portal and other means.
We proactively release the results of our annual sustainability activities to the public through integrated reports, our website and other media.

(Corporate Citizenship)

We are committed to participating in society as a good corporate citizen and providing inspiring experiences through entertainment with our full of originality. Based on this commitment, we will continue to conduct various social activities to meet society's expectations and build trust in the society.

(Raising Awareness of Sustainability Activities across the Entire Group)

While establishing the policies for the entire group and engaging in the activities we require each of our group companies to establish sustainability plans, receive reports on their performance and implement a PDCA (Plan-Do-Check-Act) cycle to evaluate and we thereby develop such activities in the entire group and their business activities.
As part of our sustainability governance structure, we have has established a Group Sustainability Subcommittee within the Group Management Committee to formulate group policies and targets, and to conduct management discussions about activities in each group company and revisions to its targets, and will regularly report the progress to the Board of Directors for further development.

SEGA SAMMY Group Environmental Policy

Basic Concept

Global environmental issues such as global warming, depletion of natural resources and waste pollution are becoming increasingly serious and the response toward environmental challenges is a top priority challenge that should be addressed by all corporations and individuals.

With the aim of achieving the “sustainable development of society,” the SEGA SAMMY Group, not only comply with the laws, regulations and rules concerning the environment, but also accumulate activities that exert a positive impact on the environment through such means as striving to conduct business activities in harmony with the environment, such as engaging in energy saving measures, recycling and reduced usage of consumables.

Basic Policy

(Compliance with Laws and Regulations)

We will properly manage any chemical substance designated by relevant laws and regulations in respect of all our products and their manufacturing processes.
We will comply with the relevant laws and regulations, etc., of the local jurisdiction concerning drainage, sludge and emissions, etc., (environmental laws and regulations such as air pollution, water pollution, waste.) and will strive to improve further through our voluntary standards as necessary.
We will get necessary permissions and approvals from applicable administrative agencies and make the required management reports.

(Matters to Achieve)

We will make continuous efforts to achieve the effective utilization of energy and resources to promote energy saving and resource conservation.
We will strive to achieve a continuous reduction in greenhouse gas emissions.
We will comply with laws and regulations such as the proper disposal, and recycling, of waste and make efforts to reduce the final amount of waste produced in the process of manufacturing.
We will make efforts toward water resource conservation, the effective use of water and the prevention of water contamination.
We will promote sustainable procurement and product development in our business activities for biodiversity conservation.

(Accountability)

With regard to our efforts on environmental practices and the results, we will promote, in an orderly manner, the consideration of performance indicators, the recognition of results (including the development of necessary procedures) and an explanation of the content of our disclosures and efforts in order to fulfill our accountability regarding SEGA SAMMY’s responses.

SEGA SAMMY Group Anti-Corruption Policy

Basic Concept

In recent years, regulations concerning bribery and corrupt practices have been strengthened globally, and the enforcement of such regulations has become stricter. Given the progress in the globalization of the SEGA SAMMY Group’s business and these regulatory developments, We recognize that addressing corruption risks is an important issue for our group.

We comply with anti-bribery laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act, as well as other applicable laws and regulations concerning the prohibition of bribery in the countries and regions where our group companies operate. We strictly prohibit the offering or acceptance of bribes to or from any public official or other individuals.

Furthermore, we require those acting on behalf of our group, as well as our business partners, to comply with the aforementioned laws and regulations to eliminate bribery from our business activities and to ensure in all business dealings involving the SEGA SAMMY Group.

Basic Policy

(Compliance with Laws and Regulations)

We will not provide, offer to provide or promise to provide any bribe, directly and indirectly, to anyone, nor will we accept any bribe or engage in any other corrupt practices. We will fully understand and comply with the anti-bribery regulations and this policy through training, and other educational programs.

(Matters We are Striving to Achieve)

Payments to public officials will be made in accordance with appropriate approval procedures or appropriate post facto/post-payment verification.
We will only execute business with agents and business partners who are legitimate and trustworthy and take appropriate procedures before executing business with them.
We will maintain internal controls on the retention of records and financial affairs, etc., in order to demonstrate our compliance with the anti-bribery regulations and this policy.
We will regularly review this policy and the internal control system and implement revisions and improvements as necessary.
In case any suspicion of violations of anti-corruption regulations, anti-bribery regulations or this policy by the SEGA SAMMY Group’s officers, employees, agents or business partners, it will be promptly reported to the relevant department to enable timely and appropriate action.