To meet the trust and expectations of our customers and society, we have established a compliance policy for all employees and officers of our group companies to ensure a thorough understanding of compliance. This document outlines the DTS Group's "Basic Compliance Principles" and "Code of Conduct." While the Code of Conduct consists of the company's basic stance and its specific application to employees and managers, only the basic stance is presented here. Furthermore, we have introduced an internal reporting system in each group company to prevent and promptly correct illegal and fraudulent activities. We have also entrusted the group-wide external reporting hotline to lawyers at Daiichi Fuyo Law Offices to ensure the fair operation of the system.
compliance
Compliance Basic Principles
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1.
We comply with laws, regulations, social norms, and company rules.
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2.
We will not pursue profits through unfair means or engage in fraudulent activities.
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3.
We constantly ask ourselves whether our actions are right and shameful "as human beings" and "as members of society," and we strive to make sound judgments and take responsible actions as employees of the DTS Group.
Code of Conduct
1. Respect for human rights and creating a rewarding workplace
[Basic posture]
- 1. We respect each other's personalities, individuality, and diverse values, and aim to create a workplace where each employee can live vibrantly and maximize their abilities.
- 2. We will instill a corporate culture throughout the company that does not tolerate or conceal human rights violations or misconduct.
- 3. We do not tolerate forced or child labor, whether direct or indirect.
2. Good relationships with customers and improved customer satisfaction (CS)
[Basic posture]
- 1. By providing optimal solutions and sincere responses, we will improve customer satisfaction and build even stronger relationships of trust with our customers.
- 2. I will not agree to any contract that violates laws and regulations, regardless of the reason.
- 3. We will ensure that the contents of the contract are thoroughly communicated to all relevant personnel (including those from partner companies) and related departments, and that they are adhered to.
3. Thorough information management and confidentiality
[Basic posture]
- 1. We will comply with relevant laws and regulations and internal company rules regarding information security, and will strengthen and continuously improve our company-wide management system.
- 2. We will promote education and awareness-raising activities to constantly raise awareness and morals regarding information security management and personal information protection among employees, executives, and partner companies.
4. Free competition and fair trade
[Basic posture]
- 1.We will comply with all applicable laws and regulations, including those applicable to our customers' industries, and conduct fair and open transactions.
- 2. We conduct business with partner companies and companies from which we purchase equipment, etc., based on agreements on an equal footing. Furthermore, we select our suppliers based on objective criteria such as technical capabilities, quality, price, and service excellence.
5.Appropriate handling of intellectual property
[Basic posture]
- 1. We will gather the latest information on intellectual property, such as patent rights and design rights, and strive to acquire rights for the DTS Group, aiming to expand our business.
- 2. We will collect the latest information on intellectual property and strive to avoid infringing or causing damage to the rights of other companies.
6. Appropriate business operations and information disclosure
[Basic posture]
- 1. We will handle the company's business operations appropriately in accordance with internal regulations, etc. We will also keep accurate and well-founded records of all transactions.
- 2. Regarding information required by law to be disclosed regarding the results of business operations (such as financial reports), we will disclose such information through appropriate procedures in accordance with the law.
- 3.When disclosing our management strategy, we will appropriately disclose our sustainability initiatives.
- 4. We will proactively and timely disclose information to shareholders and investors, and strive to increase appropriate corporate value in the market.
- 5.We will strive for smooth communication with stakeholders through information disclosure and achieve fair and transparent management.
7. Prohibition of involvement with anti-social forces
[Basic posture]
- 1. As a corporate ethical mission, we will resolutely reject any ties with anti-social forces or organizations that pose a threat to the order and safety of civil society.
- 2. Based on the basic principles of "not spending money," "not using," and "not being afraid," we will always maintain a sense of crisis management and strive to not give anti-social forces or organizations an opportunity to take advantage of us.
- 3. In the event of trouble with anti-social forces or organizations, we will respond in an organized manner, cooperating with the police, lawyers, etc., under a rapid communication system to deal with the issue.
8. Environmental and Social Contribution initiatives
[Basic posture]
- 1. We recognize that preserving the global environment is one of the most important issues facing all of humanity, and as a company that takes responsibility for the future of society, we will continue to take steps to protect the environment.
- (1) As an IT company, we will comply with environmental laws and regulations in our business activities.
- (2) We will strive to reduce the environmental impact of our offices, including resource and energy consumption.
- (3) We actively purchase socially and environmentally friendly products.
- (4) We will provide environmental education to our employees and employees of partner companies working at our facilities to raise their environmental awareness.
- 2. As a "good corporate citizen," we will fulfill our obligations and responsibilities to society and aim to realize a society where people can live with greater peace of mind. We also believe that it is important for each employee to raise their awareness of and act on Social Contribution, and we will actively promote Social Contribution activities.
Compliance Promotion System
To ensure thorough compliance with laws and regulations and corporate ethics, the Group has established an "incident reporting system" and a "compliance promotion system," and strives to operate them appropriately.
The incident reporting system is designed so that incidents are reported from the department where the incident occurred (including group companies) to the department in charge of risk, the risk management department, the corporate manager, and finally to the President. This ensures that serious risks are identified early and a system for rapid response is in place.
The Group conducts compliance training and compliance surveys every year to raise and solidify awareness of compliance.
The survey results are reported to the President and provided as feedback to all departments, and are used to make improvements across the organization.
Furthermore, the department in charge of compliance plans and operates training programs based on the survey results, and continues to improve the content. Training materials are shared with group companies to promote the improvement of compliance literacy throughout the group.
Incident reporting system
Compliance Promotion System
Track record of compliance training implementation
| Implementation year | ＤＴＳ | Domestic Group | Overseas Group | |
|---|---|---|---|---|
| 2024 | 1st | 8,058 people | 3,157 people | 539 people |
| *1 2nd session | 8,142 people | 3,137 people | － | |
| *1 3rd | 8,108 people | 3,160 people | － | |
| *2 Anti-bribery training | 3,209 people | 1,950 people | 458 people | |
| 2025 | 1st | 7,901 people | 3,157 people | 432 people |
| *1 2nd session | 7,557 people | 3,137 people | － |
*1 Target: Our company and domestic group companies (including partner companies) *2 Target: Our company and domestic and overseas group companies
Measures to eliminate anti-social forces
1. Basic principles for eliminating anti-social forces
Our company has established the following basic principles for excluding anti-social forces in the "DTS Group Code of Conduct":
- (1) As part of our corporate ethical mission, we will resolutely eliminate any ties with anti-social forces and organizations (such as corporate racketeers and organized crime groups) that threaten the order and safety of civil society.
- (2) Based on the fundamental principles of "do not give money," "do not use," and "do not be afraid," we will always maintain a sense of crisis management and strive not to give antisocial forces or organizations any opportunity to take advantage of us.
- (3) In the event of trouble with anti-social forces or organizations, we will take organized action in cooperation with the police, lawyers, etc., under a rapid communication system to deal with such incidents.
2. Status of measures taken to eliminate anti-social forces
- (1) Status of the establishment of a department in charge of response and a person in charge of preventing unreasonable demands The department in charge of response to the exclusion of anti-social forces is the General Affairs Department, and the General Affairs Department Manager is designated as the person in charge of preventing unreasonable demands.
- (2) Collaboration with external expert organizations We are collaborating with expert organizations such as the Tokyo Metropolitan Police Department, the Tokyo Metropolitan Police Department's Joint Council for Measures to Prevent Special Violence, and the Tokyo Bar Association.
- (3) Status of information gathering and management regarding anti-social forces We maintain close information exchange with external expert organizations and collect and store information.
- (4) Status of the development of response manuals The "DTS Group Compliance Handbook" clearly outlines the basic stance and specific responses to the exclusion of anti-social forces, and is used for guidance and awareness-raising.
- (5) Status of training activities We actively participate in training sessions organized by specialized organizations.
Initiatives to prevent bribery and corruption
Our group complies with all applicable laws and regulations, including those applicable to our customers' industries, and conducts fair and open transactions. In order to build healthy and favorable business relationships with our business partners, we will conduct gift-giving and entertainment with good sense and moderation, have established "Anti-Bribery Guidelines," have been made known to our executives and employees, and we conduct training on "Anti-Bribery" and other topics.
We have also established a reporting system for cases where entertainment or gifts are received from business partners, and we confirm that entertainment and gifts are provided within the bounds of good sense, that excessive entertainment or gifts are not received, and that business partners are not requesting the provision of benefits.
Concerns about corrupt practices, including bribery, can be reported and discussed through the internal reporting system.
Basic Policy
In order to thoroughly prevent bribery of domestic and international public officials and private sector parties, the DTS Group complies with the anti-bribery laws of each country in which it conducts business. In addition, we comply with all relevant laws and regulations, including those applicable to our customers' industries, and conduct fair and open transactions.
Scope of application
This policy applies to all officers and employees of the DTS Group. In addition, we have formulated the "DTS Supply Chain Responsible Business Conduct Guidelines" for our business partners, and we require them to understand, support, and practice our anti-bribery and anti-corruption efforts, working to prevent bribery and corruption throughout our business value chain.
Legal compliance
The DTS Group complies with the Japanese Unfair Competition Prevention Act, the US FCPA (Foreign Corrupt Practices Act), the UK Bribery Act 2010, the Chinese Criminal Code on Bribery, and other laws and regulations related to bribery and corrupt practices in each country.
Promotion Structure
We have clearly defined policies and rules regarding bribery prevention, and these are implemented primarily by the relevant departments. We have established a system where employees can promptly consult with their superiors or compliance officers if they have any doubts or questions. We regularly review policies and rules and revise them as necessary.
Prohibition of Bribery
The DTS Group strictly prohibits the offering, promising, providing, or receiving of improper benefits, whether directly or indirectly. Providing benefits through intermediaries or small payments for the purpose of facilitating procedures (facilitation payments) also constitutes bribery and is not tolerated as a general rule.
Handling of entertainment and gifts
The DTS Group generally prohibits the giving of entertainment and gifts to public officials, etc., and will not provide improper benefits to foreign public officials or business partners. In addition, we will establish appropriate standards and a reporting system for the receipt of entertainment and gifts from private parties as well, ensuring transparency and fairness, thereby promoting sound and trustworthy business activities.
Record keeping
To ensure transparency regarding entertainment and gifts, we manage records in accordance with anti-bribery guidelines. Receipt of gifts and entertainment is reported in accordance with prescribed procedures, and records are kept appropriately. This prevents excessive entertainment and inappropriate gift-giving and ensures the effectiveness of internal controls.
Donations and political contributions
Donations are drafted and approved appropriately in accordance with the rules of authority. Political donations are strictly compliant with laws and regulations, and transparency is ensured in accordance with internal procedures. If there are any questions, we consult with the relevant department and make decisions based on the latest external regulations.
- Political donations
We do not make political contributions.
Response to bribery and corruption
Our group does not tolerate any corrupt practices, including bribery, and will deal strictly with any violations. Bribery not only has a serious impact on a company's credibility and business continuity, but may also result in criminal liability and disciplinary action against those involved.
Dealing with business partners
Our group considers the prevention of bribery and corruption to be an issue that must be addressed throughout the entire supply chain, and we require our business partners, such as agents and subcontractors, to comply with our policies and relevant laws and regulations.
In conducting business, we will maintain a fair and transparent relationship and implement appropriate management and supervision to prevent the provision of unfair benefits or any actions that could give rise to suspicion of such benefits.
Internal reporting system (helpline)
In order to maintain sound and highly transparent corporate operations, the Group has established an internal reporting system (helpline) to detect violations of laws and regulations or acts contrary to corporate ethics at an early stage and deal with them appropriately. We have clearly defined a mechanism for protecting whistleblowers so that they do not suffer any disadvantage, and have created an environment in which they can use the system with peace of mind. We also accept anonymous reports, and the privacy of received information and personal information is fully protected under strict management.
Furthermore, we have set up a reporting hotline that can be used by group companies both in Japan and overseas, and have put in place a system that can respond in multiple languages, including English, Chinese, and Vietnamese. The existence of the reporting system and contact information for reporting are made known to employees through compliance training, and we are working to ensure that everyone can use the system appropriately.
DTS values a corporate culture that encourages speaking up and aims to conduct business activities in a fair and honest manner.
| year | Number of reports received | ||
|---|---|---|---|
| No violations | Number of corrective actions taken | ||
| 2021 | 9 | 6 | 3 |
| 2022 | 6 | 4 | 2 |
| 2023 | 8 | 2 | 6 |
| 2024 | 17 | 11 | 6 |
| 2025 | 13 | 12 | 1 |