Like citizens, corporations have social responsibilities as members of society. Monex Group, Inc. (hereinafter, "the Company") conducts management and business activities in an ethical manner while being committed to to maintaining compliance system. 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, officers, and employees (all people engaged in the Group’s operations regardless of title; hereinafter, collectively referred to as “Monex People”), and is distributing it to all Group Directors around the world.
In day-to-day operations, Monex People must strictly abide by all relevant laws and regulations as well as the Ethics and Compliance Code of Conduct. In addition, Monex People 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 in an ethical manner, 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 Monex People.
As a system to ensure the compliance with the laws and regulations at each group company, our ethics team and compliance team respectively are developing annual plans and promoting activities in accordance therewith. Executives of our group companies are in charge of these activities, and they liaise with the Monex Group team. The executive officer of the Monex Group team reports directly to the CEO and the company’s Board of Directors.
The company has put together the Corporate Ethics and Compliance Code of Conduct, which provides the standards of conduct in terms of ethics, and all officers and employees are required to strictly comply with these guidelines. In addition, the company has also established the Regulations on Management of Gift and Offerings, which are internal regulations to prevent corruption. These regulations define gifts and offerings, stipulate prohibited acts (such as incurring debt, providing or lending money, etc.) and clarify the internal procedures for the provision and acceptance of gifts and offerings. They also state that any possible violation shall be reported promptly to the executive officer in charge of internal control.
Some of major items set forth in the Regulations on Management of Gifts and Offerings.
-Definitions of gifts and offerings.
-Internal rules and procedures for the provision of gifts and offerings.
-Internal rules and procedures in case of accepting gifts or offerings.
-Investigations and rectifications
To ensure a high level of compliance awareness and to raise this awareness continuously, we are conducting the compliance training on a regular basis, including the anti-corruption & anti-bribery training, for directors, employees, part-time employees, and temporary staffs. In addition, for our Japanese operations, we share the up-to-date information on compliance at monthly company-wide meetings attended by many employees from the group companies.
The status of compliance, including anti-corruption & anti-bribery, is reported monthly to the Board of Directors for oversight by the Board. The scope of internal audits is determined based on risk assessments on the whole operations, including ethical standards and anti-corruption policies. As a result, we have been conducting audits of our anti-corruption policy for the past two years, as well as audits at each of our major group companies around every three years.
The company has established a whistleblower system, which will help us achieve early detections and prevent such acts that may damage the group’s corporate value, including not only compliance violations but also violations of workers’ human rights and other labor issues. The CEO delivers a message on the significance and importance of the system once a year to all employees of each company in the group. The confidentiality rules to protect the privacy of those who consult with the company as well as the content of the whistleblowing and consultation (“whistleblowing, etc.”) are in place and these rules are widely informed throughout the company. To ensure fairness of the system and to enable whistleblowing, etc. to be conducted in the local language and anonymously, an independent outside law firm has been designated as the contact point for whistleblowing, etc., in addition to the chairman of the Audit Committee. With e-mail, informants can contact these contact points 24/7. In addition, the company prohibits the dismissal, demotion, reduction in salary, or any other disadvantageous treatment of informants for whistleblowing, etc. In this manner, the company guarantees protection of users of the whistleblower system in accordance with the Whistleblower Protection Act.
Soon after the report is received, the chairman of the Audit Committee, depending on the actual circumstances, appoints an investment team consisting of a single or multiple members, who will be conducting investigation of the case in an appropriate manner. The system allows informants to know the results of the investigation and corrective actions to be taken. In addition, the status of relevant cases handled by our contact points for whistleblowers is reported on a monthly basis to the Board of Directors, and they are subject to the oversight by the Board.
Results in FY2022
Number of incidents due to non-compliance with Monex Group Human Rights Policy: None
Number of incidents due to non-compliance with laws, regulations or other internal policies: 2 reports
Total number of whistleblowing reports: 10 reports
*Monex Group, Inc., Monex Inc., Coincheck Inc., TradeStation Group, Inc.& Groupwide in the US Segment (Covers over 90% of the group's employees)
To prevent corruption and 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. Monex People is required to fully comprehend and strictly comply, 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’s directors, officers, and 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”) to gain advantage under the Gift and Donation Management Guidelines. In addition, under the Ethics and Compliance Code of Conduct, Monex People must not offer, request or promise bribes or have any other inappropriate dealings with transaction parties or others. It also ensures that political contributions are made in a legal and appropriate manner.
Monex People shall not directly or indirectly demand any outside parties to provide money, business entertainment, gifts, entertainment tickets, or other benefits (including kickbacks) for the purpose of gaining personal interest or misconduct, and shall not accept excessive entertainment or gifts. For acts that comply with the laws or regulations of the country or region in which the act takes place and the Monex Group's regulations, and with proper frequency and values are acceptable.
Violations to the Company’s corporate philosophy or the Ethics and Compliance Code of Conduct, as well as suspected illegal behavior, i.e. money laundering and financing of terrorism, corruption and bribery, human rights issues (including harassment), are subject to reporting to Internal Consultation and Reporting Desk, which is a whistleblowing hotline that accepts anonymous reporting. The Internal Audit Department must regularly investigate and evaluate internal controls aimed to prevent bribery in terms of their effectiveness and validity and report to Company’s Board of Directors. Based on their findings, rules and regulations shall be updated and recommend improvements. In order to demonstrate a clear intention to prevent bribery and corruption, the “Monex Group Code of Conduct” which serves as a basic guideline for all Monex People clearly states to prevent and eliminate all corrupt and criminal activities including bribery and corruption. The Code of Conduct is communicated to entire Group in a newsletter distributed to all Monex People.
Results in FY2022
Total amount of political contributions made: None
Number of incidents due to non-compliance with anti-corruption policy/policies: None
Number of staff disciplined or dismissed due to non-compliance with anti-corruption policy/policies: None
Cost of fines, penalties or settlements in relation to corruption: JPY0
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 ｍajor domestic group companies 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 ｍajor domestic group companies 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.
In order to maintain the effectiveness of these policies and systems, the Japan Segment in the Group holds regular seminars and training on AML as well as internal training to help combat bribery and corruption. Subsidiaries abroad also hold regular seminars and training on governance, anti-bribery, anti-corruption and AML. Monex Group is not just developing the financial instruments business but the crypto asset and investment businesses in Japan, the U.S. and Asia-Pacific. Therefore, the Group has a system in place to share valuable information, such as revisions to the law, at the Group's meetings or from regular reports made to the Group, to understand the differences between domestic laws and those in other countries.
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