If an employee has knowledge of or a concern about possible illegal, unethical, dishonest or fraudulent activity or conduct, or any other violation of these Principles of Employee Behaviour and Business Conduct, the employee is immediately to contact their supervisor or the person in charge of Human Resource of the relevant Group Company.
Protection for employees who report violations is provided in two important areas, confidentiality and protection from retaliation. Insofar as possible, the confidentiality of the employee will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law, and to provide accused individuals their legal rights of defense. The relevant Group Company will not retaliate against any employee for reporting possible wrongdoing. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any employee who believes he/she is being retaliated against must contact the Human Resources Manager or supervisor immediately. The right of an employee for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated. Further, an employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.
Any report of alleged illegal, unethical, dishonest or fraudulent activities or conduct, or other violations of these Principles of Employee Behaviour and Business Conduct will be referred by the relevant supervisor or person in charge of Human Resource of the relevant Group Company to the Managing Director and/or President and to corporate administration of the relevant Group Company, who, in turn, will report the matter to the Managing Director of the Company. The Company shall promptly investigate the allegations and take appropriate corrective action.
The relevant Group Company will take prompt and necessary steps to investigate any report of illegal, unethical, dishonest or fraudulent activity or conduct, or other violations of these Principles of Employee Behaviour and Business Conduct. The scope of the investigation will depend on the nature of the report and the related circumstances. In each instance, the relevant Group Company will endeavour to handle the investigation with as much discretion as is appropriate under the circumstances, in an effort to protect the privacy of the persons involved, but absolute confidentiality cannot be guaranteed.
If the investigator finds that the allegations are true, appropriate action will be taken. Any employee of the relevant Group Company who is found to have engaged in any form of illegal, unethical, dishonest or fraudulent activity or conduct, or other violations of these Principles of Employee Behaviour and Business Conduct, will be subject to disciplinary action up to and including termination. The relevant Group Company will also take any other action which is appropriate under the circumstances.