Compliance

The EBARA Group strives to act as a good corporate citizen that earns the trust of stakeholders. For this reason, the EBARA Way and the EBARA Group Code of Conduct are shared among all employees to form a common identity and set of values. With this as the foundation, it is our basic policy to practice strict legal compliance, adhere to internal rules and social norms, and act with common sense, good intentions, and integrity.

The EBARA Group has established compliance consultation hotlines to create a comfortable workplace and enhance the ability to voluntarily improve internal problems. We have implemented various measures to familiarize employees with their use.

In Japan, each Group company has its own hotline and is in charge of its operations. The Company and Group companies with more than 300 employees have established an internal whistleblower response system in compliance with the revised Whistleblower Protection Act. Other Group companies are also developing internal whistleblower response systems in compliance with the revised Whistleblower Protection Act, taking into consideration the circumstances of each organization.

At overseas Group companies, we continue to strengthen overseas EBARA Group hotlines, which are designed to increase the transparency of Group companies, strengthen the internal capabilities of these companies, and to support their healthy and autonomous operation.

1. Prevent improper activity before it happens
2. Quickly detect improper activity that may have occurred
3. Create comfortable workplace environments
4. Foster internal capabilities for resolving issues
5. Maintain the confidentiality of and protect those who consult

The EBARA Group has established both internal and external compliance consultation hotlines to facilitate the prompt resolution of compliance issues that may arise during the course of everyday operations. These hotlines enable stakeholders to report concerns or blow the whistle regarding non-compliance directly to the department in charge of compliance, the Audit Committee Office, or an external law firm.

We have implemented internal regulations regarding the operation of both internal and external consultation hotlines. The internal regulation stipulates that the privacy of the complainants, the subjects of the consultation, and related parties will be protected, and that the consultants will not be disadvantaged for making their consultation.

Consultation/whistleblowing is widely accepted from executive officers, directors, employees, their families, business partners, and other stakeholders. Upon receipt of a consultation, the internal department in charge of compliance conducts an investigation and takes appropriate action to resolve the issue.

The operation status of the hotlines is reported to the Sustainability Committee, chaired by all executive officers and attended by directors. The deliberations of the Sustainability Committee are reported to the Board of Directors and appropriate oversight is conducted. 

In FY 24, a total of 57 consultations were received. Including unresolved cases carried over from the previous year, investigations were conducted for 91 cases in total. Of these, responses were completed for 66 cases, broken down as follows: 1 was regarding the work environment and related issues, 20 regarding inappropriate behavior, 3 regarding potential legal violations, 6 concerning potential harassment, and 36 others. The remaining 25 cases are still under review.

With the aim of promoting continued compliance and establishing a group-wide framework to address compliance-related issues in coordination with our overseas group companies, we held Compliance Liaison Meetings up until fiscal year 2023.

From fiscal year 2024 onward, the scope has been expanded to cover overall risk management, and the framework has been reorganized into the CRO Liaison Meetings. These meetings involve participation from the Corporate Division as well as companies overseeing group subsidiaries, enabling the sharing of a wide range of compliance-related information.

In fiscal year 2024, liaison meetings were held with 34 subsidiaries across the North and South America region, the Europe and Middle East region, the Asia and Oceania region, and the Africa region.

• Sharing of compliance-related educational materials on the intranet
• Sharing operating results of the Compliance Consultation Hotline internally twice a year, and communicating the types of issues being reported within the company
• Sharing of compliance educational materials, including those regarding harassment, twice a year with domestic group compliance officers
• Assign Compliance Liaison Committee members* (121as of February 1, 2025) to workplaces nationwide, including domestic subsidiaries, and provide training on compliance, including regarding harassment
• Distribute compliance educational materials, including those regarding harassment, monthly to workplaces via Compliance Liaisons

*Compliance Liaisons are nominated by each department at EBARA Group companies domestically, and are assigned to workplaces nationwide to act as on-site easily-approachable people to consult regarding compliance concerns or questions. They are also responsible for spreading compliance awareness in the workplace, picking up compliance risks, and early detection and resolution of compliance-related problems.

Since June 1, 2020, the President has disseminated the following message to all employees of the EBARA Group, calling for all to not commit, allow, excuse, or cover up harassment.

Mar. 27, 2025

To EBARA and Group Companies

Shugo Hosoda
President and Representative Executive Officer
EBARA Corporation

Harassment is an act that threatens human rights, damages the dignity of employees, and leads to a deterioration of the work environment. In addition, there must be no harassment not only within the company, but also in the treatment of employees of business partners and other business partners and the Company's job applicants.

The EBARA Group does not tolerate harassment at all, and is working to create a safe, secure, and high-performance work environment in which all stakeholders respect each other.

The EBARA Group has established a consultation desk to resolve harassment and other issues. We will not treat the consulter or anyone who has cooperated in confirming the facts in a disadvantageous manner, and commit to protecting the privacy of those involved. We protect your privacy.

We will continue to provide training for our employees. Let's learn about harassment and try to create a corporate culture that does not allow harassment to occur.

Let all employees of the EBARA Group strive to "not harass, do not allow it, do not tolerate it, and do not overlook it" and make it a company where each and every one of us can work with pride.

Thank you for your cooperation.