Prevention of bribery and corruption

Anti-bribery and corruption policy

1. Anti-bribery policy

Officers and employees of the Orion Group correctly understand and comply with the applicable anti-bribery laws and regulations of the countries and regions where it operates. We shall not offer, demand, promise, give or accept, directly or indirectly, a bribe from anyone. Bribes include, but are not limited to, the giving or receiving of anything of value such as cash or gifts, personal favors or entertainment, and meals and travel expenses.

Officers and employees of the Orion Group shall not engage in any form of bribery of public officials or others.

2. Anti-corruption policy

Officers and employees of the Orion Group are committed to achieving the highest ethical and legal standards in all aspects of business activities. We correctly understand and comply with the Unfair Competition Prevention Act of Japan and anti-corruption laws and regulations of the countries and regions where we operate. We shall not engage in money laundering, extortion, or any other form of corruption. In accordance with this policy, officers and employees of the Orion Group shall not directly or indirectly offer or present anything of value (cash, gifts to relatives, debt forgiveness, loans, personal favors, excessive entertainment, meals or travel expenses, political or charitable contributions, business opportunities, the provision of medical care, etc.).

Anti-bribery and anti-corruption initiatives

The Risk Management and Compliance Committee provides all officers and employees, including those of Group companies, with the necessary training on a regular and ongoing basis. Specific examples of bribery are cited to avoid behavior that might raise suspicion. We have established a whistleblower hotline, and in the event of a suspected case of bribery or corruption, Corporate Auditors and the Office of Internal Audit take the lead in gathering information and conducting an investigation, and appropriate measures will be implemented.

Specific initiatives

  • Anti-corruption initiatives by the Board of Directors
  • Establishment of the Risk Management and Compliance Committee
  • Compliance training
  • Establishment of a whistleblower hotline
  • Investigations by Corporate Auditors and the Project Director of the Office of Internal Audit
  • Reporting to top management

Due diligence of new business partners

The Orion Group decides whether to engage in transactions with business partners, taking into consideration such factors as the quality of raw materials used, technical level, supply capacity, delivery time, price competitiveness, degree of management stability, legal compliance, and absence of any relationship with antisocial forces. The Regulations for Response to Antisocial Forces govern investigations concerning relationships with antisocial forces, and the Related Party Management Regulations stipulate procedures for investigating whether prospective business partners are within the scope of related parties.

Political contributions made

The Orion Group recognizes the importance of maintaining relationships with Diet members elected in Okinawa Prefecture and high-ranking political party officials to support the development of both the Company and Okinawa Prefecture. We use an account titled “political party-related expenses” for the treatment of such expenses. Political party-related expenses include the cost of purchasing tickets to receptions, policy workshops, promotional seminars, etc. held by political parties and political organizations.

  • Results for fiscal 2022 (April 1, 2022-March 31, 2023)
    1,390,000 yen per year
  • Budget for fiscal 2023 (April 1, 2023-March 31, 2024)
    1,400,000 yen per year

In fiscal 2022, the Orion Group was not subject to any fines, penalties, or settlements in relation to corruption.