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.
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.

Familiarity with the Group Code of Conduct

The SEGA SAMMY Group complies rigorously with corporate ethics and statutory laws and regulations by ensuring all employees of the Group understand the Group CSR Charter and by providing guidance on conduct and performance of duties consistent with the spirit of this charter in the Group Code of Conduct and the Group Management Policy.

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

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.

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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