Fair Operating Practices

Basic Standpoint

We recognize that the establishment of corporate ethics and compliance are the basis of corporate management. We have made this policy explicit in the Action Guidelines for Taisei Personnel and the Taisei Group as a Whole and various rules and regulations, and take various measures to encourage the autonomy and awareness of every officer and employee.

Compliance Committee

We have established a Compliance Committee comprising of outside experts as well as directors of our company, which makes proposals to the President on specific measures for promoting compliance.

Specific efforts

1. Development of internal systems for promoting compliance behavior

For providing company-wide promoting systems to raise awareness of and provide education for compliance, the company develops an organization led by the President and appointing compliance managers, compliance supervisors and compliance leaders in individual divisions, branches and departments.

Compliance Section

The company establishes the Compliance Section within the Legal Department, which serves as a secretariat for the Compliance Committee and devotes itself to raise the awareness of its executives and employees for compliance culture.

Compliance Leaders

Positioning the promotion of compliance policy as an integral part of its business activities, the company assigns the general managers of every department to act as compliance leaders. By positioning the general managers as key personnel to educate all executives and employees who belong to their departments, the company provides company-wide compliance promoting systems.

2. Development of business systems to prevent unreasonable bidding practices

To prevent unreasonable bidding practices, the company formulates rules that require general managers of branch offices and project divisions to check steps in bidding procedures such as bidding policies, reasons for setting up joint ventures, sales activities and cost assessments in order to verify that proper bidding practice is carried out, and establishes procedures for the preparation and preservation of such verification records and the internal auditing system (Procedures for ensuring the appropriateness of bidding practices).

3. Adoption of strict rules for disciplinary measures for executives and employees concerning violations of laws, etc.

In the President's message about compliance with laws, the company states its policy to implement strict disciplinary measures for violations of laws and regulations based on the company rules, and sets out rules for internal disciplinary measures for employees as well as executives.

4. Declarations submitted by executives and employees

The company demands that all executives and employees should submit a declaration that states compliance with laws and regulations, active participation in compliance training sessions, consultation with the General Manager of Legal Department about dubious cases, obligation to report activities that may cause serious damage to the company, and agreement to the implementation of strict disciplinary measures.

5. Obligation to report serious violations of laws

The company imposes on employees an obligation to report activities that may cause serious damage to the company such as exclusion from bidding or suspension of business activities.

6. Implementation of Strict rules regarding the employment of retired government officials

The company sets out strict rules regarding the employment of retired government officials, and makes it a rule to seek opinions of the Compliance Committee before making decisions at the board of directors on important personnel issues.

7. Improvement of the Corporate Ethics Helpline

The company provides an internal reporting system, the "Corporate Ethics Helpline," to help employees report violations of laws and regulations and other compliance-related matters. The access to the Helpline is provided through the company intranet website menu with an option of "reporting" or "consultation", with which the use of the Helpline is expected to be enhanced.

In addition, the company sets up a contact point for the Helpline in an external law firm, and at the same time, puts up posters in every departments to increase people's awareness.

The company also provides contact points for reports from employees of our business partners, and posts a manual to how to report to us on our official website.

Since January 2009, we have expanded the scope of this program to cover our 25 group companies in Japan, and are engaged in establishing the Taisei Group Compliance system.

8. Compliance auditing by the Legal Department

The Legal Department carries out an annual audit in regard to the implementation of the procedures for ensuring the appropriateness of bidding practices, compliance with construction industry laws and regulations and the implementation of compliance training in all branch offices and operations headquarters.

In addition to the above activities, an audit was conducted in FY 2009 to verify the status of compliance in relation to the provisions of the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors.