Compliance

JDI Ethics

JDI is fully committed to not only complying with laws and regulations but also a system of management that observes corporate ethics. JDI has created "JDI Ethics" to provide specific guidelines to all managers and employees on the importance of respecting compliance rules. A pocket-size version of JDI Ethics has been distributed and education is conducted to further promote compliance awareness among managers and employees. Also, an English-version of the Code has been distributed to JDI's overseas companies and is widely promoted.

Compliance

In accordance with the Fundamental Policy for Compliance, JDI has instituted the Compliance Committee as a forum where representatives from related units deliberate and implement measures to establish and inculcate compliance promotion systems and programs. A compliance administrator is assigned to each division to ensure awareness of compliance measures among the employees of each division.
The Compliance Committee is supervised by the chairperson appointed by the Board of Directors and consists of the representatives of divisions that prepare compliance-related policies and measures. The Committee meets once every half-year and holds extraordinary meetings as necessary. Furthermore, the Meeting of Compliance Administrators is held, which is a venue for deepening understanding of the results of deliberations by the Compliance Committee and for information sharing among compliance administrators.

Compliance System

Whistleblower System

JDI has instituted the Whistleblower System to enable the prevention and early detection of compliance violations, increase flexibility in the self-policing process, and correct compliance violations and, in so doing, ensure public trust in JDI. Employees who have discovered compliance violations or suspected violations can use the Whistleblower System to seek consultation and make reports. As such, the system helps to instill compliance awareness in employees.
JDI has set an outside point of contact in addition to an in-house point of contact as contacts for the Whistleblowing System, as well as enabling reporting directly to the Audit Committee, and, in accordance with JDI's regulations, explicitly prohibits any disadvantageous treatment of a whistleblower while taking due measures to protect whistleblowers, such as managing whistleblowing information as strictly confidential.

Whistleblower System

Information Security Policy

JDI Group recognizes that each and every business activity is deeply connected with the issue of information protection, considers information protection as one of the priority issues of management, and is committed to establish an information management system and continuously improve the system.

Prioritized themes

• We make efforts to enhance the information security in order to prevent the loss, leakage & theft, vandalism & tampering, cover-up & destruction, and failure & destruction of the system, etc. caused by internal or external improper activities.
• We make efforts to put the information security related equipment and environment in place in order to protect our information property and information systems from human and natural disasters.
• We will keep all its employees informed about this information security policy and provide through information security trainings, and also ask involved business partners for cooperation to secure our information security activities.

Information Security System

To avoid the risk of leakage of various types of information handled by JDI, JDI has established the Policies on Information Security and other rules and takes steps to ensure all officers and employees are familiar with the rules and that they are properly implemented. JDI instituted the Information Security Committee to implement groupwide information security-related measures. The Committee conducts risk assessment and risk management and engages in continuous activities to prevent the loss, leakage, or theft of confidential information. The Committee also supervises the safeguarding of information assets and the establishment of information management systems in response to the actual conditions of each business field.

Trade Compliance policy

One of the basic principles of JDI Ethics is the compliance with import and export-related laws and regulations. In addition, JDI has established internal rules such as Compliance Policy on Import and Export to comply with Japanese Foreign Exchange and Foreign Trade Act, Japanese Customs Act, the U.S. Export Control Regulations (EAR) and other laws and regulations related to imports and exports. Our Compliance Policy on Import and Export stipulates the following basic compliance policy on import and export.

• ①With regard to exports, brokering/transshipment transactions and technical brokering transaction of controlled items and technology, any actions against Foreign Exchange and Foreign Trade Act, etc. shall not be conducted.
• ② Action violating EAR shall not be conducted with regard to the re-export of U.S. goods and technology.
• ③In order to comply with Foreign Exchange and Foreign Trade Act, etc. and the other import and export related rules and to execute appropriate import and export control, a person responsible for trade compliance is assigned, and will be maintaining/improving the trade compliance system.

Trade Compliance system

Foreign Trade Affairs Department has been established under Chief Trade Compliance Officer, who is also a Representative Executive Officer, as a Administrative Department of Trade Compliance which includes Security Export Control. The Corporate Officer of the Foreign Trade Affairs Department has the final authority for decisions of JDI's transactions, and conducts trade compliance within JDI Group as Trade Compliance Officer. Head of each Business Unit is responsible for trade compliance of the respective Business Unit as a Trade Compliance Administrator. Representatives of JDI subsidiaries are responsible for complying with the import and export-related laws and regulations of country/area in which they are located as Compliance Administrator.

Security Export Control (Classification of controlled items Determination and End-user/End-use Screening)

To determine whether or not the exported goods/technology (including software) are within the scope of Export License by the Minister of Economy, technological departments make the primary classification followed by the secondary classifications by the Foreign Trade Affairs Department.
For End-user/End-use Screening, Foreign Trade Affairs Department reviews and approves the results of screening by the division conducting the transaction. In addition to Foreign Exchange and Foreign Trade Act, EAR is also subject to classification and end-user/end-use screening.

Compliance with Customs Law and other import and export related laws and regulations

We have established internal procedures to ensure that cargo is properly imported or exported after confirming whether or not it is subject to restrictions under import and export laws and regulations. In addition to customs laws such as import/export declaration, customs valuation and bonded management in each country/region, we properly follow laws and regulations other than customs compliance such as chemicals, hazardous goods, and waste.

Audit

Internal Audit Department conducts internal audit of the JDI trade compliance system and Foreign Trade Affairs Department to each Business Unit basically once a year. The findings are reported to Chief Trade Compliance Officer and to Trade Compliance Administrator of the respective Business Unit.

Education

Foreign Trade Affairs Department conducts annual e-learning on Trade Compliance for the entire company, and conducts educations for classification of the controlled items, end-user/end-use screening and customs valuation for related departments more than once a year.

Management System for Public Research Funds

The management system properly utilizes and manages public research funds under the following system of responsibility.

System of Responsibility

Whistleblowing Inquiries or Reports

Inquiries concerning improper use of public research funds or improper conduct in research activities (forgery, falsification, plagiarism, etc.) or reports of such improper activities can be made by completing the "About Research and Development" section in the "Inquiries about products and others” form available at Contact Us.