Compliance

We established the EIZO Group Principles of Conduct—Seven Promises as guidelines for conducting business activities with integrity in consideration of the environment, human rights, and ethics toward achieving our corporate philosophy of “enriching future society through imaging solutions.” The Principles of Conduct express our commitment to stakeholders regarding our approach to sustainability and at the same time represent the standards on which we base our decisions and actions in our business activities. The principles have been thoroughly disseminated to all executives and employees of the Group. When revised in FY2021, the Principles of Conduct were translated into multilingual languages and distributed to overseas Group companies. In addition, we established the EIZO Group Human Rights Policy in FY2022 and the Anti-Bribery Regulations in April 2023 to reinforce the principles. We will continue to improve them as the Group and our business model evolve and our external environment changes.

① Implementation of a Compliance Program by the Compliance Committee

The Compliance Committee identifies and evaluates compliance risks within the Group each fiscal year in accordance with Regulations on Compliance, and develops and implements a compliance program that includes necessary preventive and corrective measures. Representative compliance risks to be identified include factors that would inhibit fair business, activities that might lead to corruption (business integrity risk), and the danger of leaking confidential information. We comprehensively examine potential risks to the Group and evaluate the materiality of risks based on the likelihood of their emergence and impact.

② Checking and Improving the Compliance Program

Every year, we monitor implementation details and insufficient results in our compliance program based on the regulations. In addition, we periodically review our Regulations on Compliance to continue to improve compliance management.

In accordance with the Regulations on Internal Whistle-Blowing, we have established internal whistle-blowing systems in all Group companies worldwide. Also, we strive to ensure the early detection and prevention of serious incidents that could damage corporate value, such as illegal activity or misconduct. Contact points have been set up inside the company and at independent law firms, and all EIZO members are expected to report any legal or ethical business issues, compliance questions, or concerns immediately, regardless of their own involvement. To make the system more accessible, explanatory materials were translated into multilingual languages and distributed to overseas Group companies in FY2021. In addition, we have taken action to alleviate concerns about whistleblowing, such as by clarifying the procedures for doing so, protecting the privacy of whistle-blowers, and prohibiting any negative impact on them. We keep improving the content and operation of the regulations so that the system will be used without anxiety and effective for self-correction.

Number of Whistle-Blowing（ESG Data）

We became a regular member of the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) in April 2024 and are working to develop the grievance mechanisms required by the UN Guiding Principles on Business and Human Rights.
JaCER provides a non-judicial "Engagement and Remedy Platform" for the redress of grievances based on the Guiding Principles.
Through this platform, we accept complaints and reports of violations and alleged violations of human rights and other responsible business conduct from a wide range of external stakeholders, including our global supply chain.

Grievance Mechanism (Remedy) (Respect for Human Rights)

In accordance with the Regulations on Internal Whistle-Blowing, we have established internal whistle-blowing systems in all Group companies worldwide. Also, we strive to ensure the early detection and prevention of serious incidents that could damage corporate value, such as illegal activity or misconduct. Contact points have been set up inside the company and at independent law firms, and all EIZO members are expected to report any legal or ethical business issues, compliance questions, or concerns immediately, regardless of their own involvement. To make the system more accessible, explanatory materials were translated into multilingual languages and distributed to overseas Group companies in FY2021. In addition, we have taken action to alleviate concerns about whistleblowing, such as by clarifying the procedures for doing so, protecting the privacy of whistle-blowers, and prohibiting any negative impact on them. We keep improving the content and operation of the regulations so that the system will be used without anxiety and effective for self-correction.

Established on January 31, 2024

EIZO Corporation and all EIZO Group Companies (hereinafter collectively referred to as the “EIZO Group”), have established the “EIZO Group Principles of Conduct”, which are to be strictly adhered to by all individuals working in the EIZO Group.
One of the principles is, "We comply with the letter and spirit of the law and act ethically." It expresses our belief that each of us must not only comply with laws and regulations, but also always behave honestly, fairly, and impartially with high ethical standards beyond those required by society. This is fundamental for earning the trust of society and stakeholders.
With this consideration, we hereby establish the EIZO Group Anti-Bribery Policy (hereinafter referred to as the “Policy”) for the purpose of preventing all acts related to bribery and corrupt practices.

1. Basic Policy

1. (1) We never engage in any illegal provision of benefits^*1 to public officials^*2, irrespective of their country or nationality.
2. (2) We never provide or accept any benefits that violate public order and morals or deviate from socially accepted norms in relationships with companies or individuals, irrespective of their country or nationality.
3. (3) We comply with all laws, regulations, and guidelines related to bribery in all countries and regions where we conduct business activities (collectively referred to as, "anti-bribery laws and regulations"^*3).

2. Scope of Application

This Policy applies to all individuals working within the EIZO Group (hereinafter referred to as "Officers and Employees"). We expect our suppliers and business partners to support this Policy.

3. Prohibition of Bribery

3-1 Bribery of Public Officials

1. (1) We do not provide benefits to public officials with whom we have business relations, especially with wrongful intent.
2. (2) We do not provide benefits that are deemed socially unacceptable, even to public officials with whom we have no business relations.
3. (3) We do not make facilitation payments^*4.

3-2　Bribery of Non-Public Officials

1. (1) We do not provide benefits to companies or individuals, including business partners, with wrongful intent.
2. (2) Even without wrongful intent, we do not provide benefits to companies or individuals beyond what is deemed socially acceptable.

4. Prohibition of Accepting Bribes

1. (1) We do not accept any benefits from others with wrongful intent.
2. (2) We do not accept any benefits from others that are deemed socially unacceptable, even without wrongful intent.

5. Record Keeping

1. (1) When providing benefits to public officials or companies/individuals in a manner that does not violate this Policy, we will do so only with prior approval from EIZO Group authorities and will create and maintain accurate records of such benefits.
2. (2) To fulfill accountability for compliance with this Policy, we factually and accurately record all such transactions and archive related documentation in accordance with the internal regulations of each company within the EIZO Group.

6. Consultation, Reporting, Whistleblowing, & Cooperation with Investigations

1. (1) EIZO Group establishes appropriate consultation, reporting and whistleblowing systems to ensure compliance with the Policy by Officers and Employees, and to prevent and correct any conduct by Officers and Employees that violates this Policy.
2. (2) In the event of any actions related to bribery, accounting irregularities, or any conduct that could lead to the suspicion of bribery or accounting irregularities, we must immediately consult, report, or whistleblow to the reporting channels or the compliance section of each company within the EIZO Group. In addition, we will fully cooperate with any investigation conducted by the EIZO Group.

7. Implementation of Internal Education

EIZO Group regularly provides education on anti-bribery to Officers and Employees to ensure thorough awareness and understanding of this Policy.

8. Risk Assessment & Review

EIZO Group will regularly assess the risk of bribery and, as necessary, review this Policy, related internal rules, and measures based on this Policy.

Mr. Yoshitaka Jitsumori
President & CEO

1. *1 "Benefits" means any tangible or intangible benefits, direct or indirect, including financial and non-financial benefits, promises of acts or omissions expected by the other party.
2. *2 "Public Official" means an individual falling under any of the following categories:
   1. (a) Those engaged in the public service of the government or local public entities (hereinafter collectively referred to as "government, etc.").
   2. (b) Those deemed to be an official engaged in public service according to laws and regulation.
   3. (c) Those engaged in the affairs of government-related agencies.
   4. (d) Those engaged in the affairs of public enterprises granted benefits by the government, etc.
   5. (e) Those engaged in the public services of international organizations.
   6. (f) Those delegated authority by a government, etc. or an international organization to conduct its affairs.
3. *3 "Anti-bribery laws and regulations" means the laws and guidelines related to bribery in each country, including criminal laws, company laws, unfair competition laws, the U.S. Foreign Corrupt Practices Act, and the U.K. Bribery Act.
4. *4 "Facilitation payment" means small payments requested by a public official, without legal basis in relevant laws and regulations, such as an application for customs clearance, censorship, or issuance or extension of an entry or stay visa and other similar processes.