Compliance and Risk Management

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. Meanwhile, the Group takes a comprehensive approach risk management to be prepared in case of large-scale disasters, new strains of influenza, and other potential risks.

Familiarity with the Group Code of Conduct

Conscientious behavior is outlined in the Group Code of Conduct, ensuring that all SEGA SAMMY Group employees understand the CSR Charter, on which it is based. Because the code should be known and practiced throughout the Group, we have also distributed a CSR Guidance that presents the code with the Group Mission, Group CSR Charter, and other relevant information. This information is also available on the intranet.

Awareness of Compliance Issues

To foster compliance awareness and make this awareness pervasive, the SEGA SAMMY Group holds study sessions for Group companies as needed. The compliance handbook gives specific examples of issues employees may encounter routinely. This handbook has been revised for clarity, and all employees can review the information on the intranet. To strengthen the internal framework that ensures timely subcontractor payment according to relevant regulations, compliance audits are conducted regularly, and our legal affairs units educate and provide guidance to all departments.

Whistleblower System

To help ensure fair and lawful business practices, a whistleblower system consistent with the Group CSR Charter was created to enable anonymous reporting by employees about potential regulatory violations or lapses in judgment, which protects the identity of tipsters. Whether reported internally or to specified law firms, these matters are investigated and rectified, and steps are taken to prevent recurrence.

Preventing Insider Trading

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.

Appropriate Processing of Donations, Prevention of Corruption

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.

Emergency Preparedness

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.

Stronger Information Security

In the SEGA SAMMY Group, all information is viewed as a valuable asset, whether it pertains to customers, management, or sales. An information security policy and rules on information management prescribe management and storage of confidential corporate information and other information.

Basic Stance on Intellectual Property

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.

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