Thinking behind ethics and compliance
Like citizens, corporations have social responsibilities as members of society. Monex Group, Inc. (hereinafter, "the Company") conducts management and business activities with high ethical standards backed by an unwavering commitment to compliance. The Company and its subsidiaries (hereinafter, collectively referred to as “the Group”) recognize that strict adherence to laws and regulations and observance of social norms are vital not only from a public perspective but also in terms of earning the stable and ongoing trust of our customers and business partners, which helps to maintain and enhance the Group’s corporate value.
Based on the above, the Group has formulated the Ethics and Compliance Code of Conduct, which defines specific action guidelines for directors, executive officers, officers, executive directors and employees (all people engaged in the Group’s operations regardless of title; hereinafter, collectively referred to as “Directors”), and is distributing it to all Group Directors around the world.
In day-to-day operations, Directors of the Group must strictly abide by all relevant laws and regulations as well as the Ethics and Compliance Code of Conduct. In addition, Directors and employees are expected to adhere to laws and regulations and act as good citizens in the local communities in which they live. The various individual and concrete management decisions and business activities of the Group must be made and implemented with the highest ethical standards and the interests of society in mind. To ensure the strict and ongoing observance of the above-mentioned policy, the Group will continuously strive to enhance the relevant systems throughout the entire Group and maintain and elevate the morals of the Directors.
Prevention of Bribery
To prevent bribery, the Company has enacted the Gift and Donation Management Guidelines, which are action guidelines regarding gift giving based on the Ethics and Compliance Code of Conduct. Company Directors (directors except outside directors, executive officers and executive directors) as well as employees (all people engaged in the Company’s operations regardless of title or employment status, including temporary and part-time employees; hereinafter, collectively referred to as “Company Directors/Employees”) are required to fully comprehend and strictly comply with these guidelines, which have been formulated with the aim to ensure impartial and independent decisions and to eliminate conflict of interest in all transactions with outside parties.
Company Directors/Employees are strictly prohibited from offering or accepting gifts or entertainment with government officials or persons equivalent to government officials (hereinafter, “government officials and others”) under the Gift and Donation Management Guidelines. In addition, under the Ethics and Compliance Code of Conduct, Directors of the Group must not offer, request or promise bribes or have any other inappropriate dealings with transaction parties or others.
Violations to the Company’s corporate philosophy or the Ethics and Compliance Code of Conduct, as well as suspected illegal behavior, including bribery, are subject to reporting in accordance with the Internal Consultation and Reporting System. The Internal Audit Department must regularly investigate and evaluate internal controls aimed to prevent bribery in terms of their effectiveness and validity and based on their findings, recommend improvements.
Anti-Money Laundering / Counter Financing of Terrorism (AML/CFT) Policy
To help maintain a healthy financial system, Monex Group (hereinafter, the “Group”) has established the Monex Group Anti-Money Laundering and Counter Financing of Terrorism Regulations (hereinafter, the “Monex Group AML/CFT Regulations”) and Compliance Policy on Anti-Money Laundering and Combating Financing of Terrorism (hereinafter, the "Compliance Policy"). The Group is undertaking measures to combat money laundering and the financing of terrorism.
In accordance with the Monex Group AML/CFT Regulations and the Compliance Policy, the division in charge of AML/CFT risk management at each of the Group’s companies (if there is an intermediate holding company, through such intermediate holding company) shall report the status of AML/CFT measures to the company person in charge of the Group’s AML/CFT measures (hereinafter, the “Group AML/CFT Head”) at the Internal Control Committee meeting held every quarter with global members of the Group. In addition, the Monex Group AML/CFT Regulations require that the Group AML/CFT Head share information with the person in charge of AML/CFT at each of the Group’s major domestic subsidiaries approximately every three months and report on the management status to the Company’s Board of Directors. Furthermore, every month, the Group AML/CFT Head collects the report of the status of measures for AML/CFT from the person in charge at each subsidiary and attends a compliance meeting with each of the Group’s major domestic subsidiaries for a full awareness of all issues and responses related to AML/CFT.
For AML/CFT risk management of the Group, each company and relevant division will take appropriate mitigation measures according to the level of risk using a risk-based approach. The approach is to properly manage the three lines of defense in management control, identification and evaluation of risks, risk mitigation measures and the reporting system to ensure the formation and maintenance of a robust AML/CFT risk management plan.