Corporate Ethics

Over the years, we have striven to earn and maintain the trust of our customers and the communities we serve by upholding our corporate philosophy. We not only comply with laws and regulations, but also take a course of action to foster a strong awareness of ethics. The Group continues to ensure strict adherence to corporate ethics by implementing specific measures of compliance.

Policies and Standards for the Establishment of Corporate Ethics

Obayashi Code of Conduct within the Obayashi Basic Principles stipulate strict adherence to corporate ethics. Throughout the Company, top management leads the effort for corporate ethics.

In order to stay aware of corporate ethics and create a sound corporate culture, we have expressed our strong determination to comply with laws and regulations and maintain high ethical standards, in our Articles of Incorporation.

Obayashi Corporationʼs Articles of Incorporation

Article 3 (Compliance and Sensible Course of Action)
In the Corporation each employee and board member shall observe laws and regulations, and maintain high ethical standards in their business activity. Particularly in regard to contracts for construction works, they should not take any action that would harm the equity and fairness of the tender, such as actions that violate the Penal Code and the Antimonopoly Act (Act on Prohibition of Private Monopolization and Maintenance of Fair Trade).

Structure to Ensure Adherence to Corporate Ethics

Obayashi has established the Obayashi Corporate Ethics Program in an effort to prevent pay-offs, bribery, and all other types of corruption that violate criminal law, the Antimonopoly Act, and other laws.

The president serves as the chief ethics officer of the Corporate Ethics Program, executive officers at the main office and the general managers of each branch serve as corporate ethics officers, and the managers of each department serve as corporate ethics promoters. Top management are responsible for corporate ethics. They recognize their own roles in realizing the spirit embodied in the Obayashi Basic Principles and work diligently to ensure compliance with corporate ethics.

Moreover, the Corporate Ethics Committee is positioned as the core of Obayashi's corporate ethics structure in the internal control system approved and reviewed by the Board of Directors every year. The Corporate Ethics Committee is chaired by the president and its members include directors, executive officers, external experts, and the head of the labor union. It operates according to the Corporate Ethics Committee Rules. The committee raises awareness of corporate ethics, formulates measures to ensure compliance with corporate ethics, monitors for legal violations or corruption, bribery, or other improper activity, investigates to determine the facts in cases involving corporate ethics violations, and formulates measures to prevent recurrence. Each branch has established a Branch Corporate Ethics Committee and implements independent activities to promote corporate ethics.

Obayashi Group Internal Reporting System

We have established a Corporate Ethics Reporting System for people associated with the Obayashi Group (employees, seconded employees, employees accepted on assignment, part-time employees, suppliers, etc.). This system serves as a hotline for all types of suspicions and problems relating to corporate ethics in the workplace, including prevention of fraud, harassment, legal violations, pay-offs, bribery, and other types of corruption. We have established an external hotline at a law firm in addition to the internal hotline, and have established an environment that makes it easy for reporters to use the system by enabling them to choose the means via which they report--by phone, email, or by post. They can report anonymously and Obayashi ensures that reporters are protected against unfair treatment. When a report is received, an investigation is conducted immediately to determine the facts, and the necessary steps are taken.

The Secretariat of the Corporate Ethics Committee also reports the contents of reports, results of investigations, and corrective steps taken to Obayashi's Audit & Supervisory Board Members. The Board of Directors also confirms proper operation of the system and reporting status when confirming the status of establishment and operation of the internal control system.

Introduction, Implementation, Verification, and Improvement on Specific Measures to Establish Corporate Ethics

In the Corporate Ethics program, Obayashi set out policies and standards, established systems, and introduced specific measures, which we are rigorously implementing.
By periodically inspecting and reviewing the status of their implementation, we strive to continue an enterprise capable of continually maintaining and enhancing its high ethical standards.

1    Rules and manuals for individual aspects of corporate ethics practice
We have set forth and abide by rules and manuals for individual aspects of corporate ethics practice. These include the Antimonopoly Act Compliance Program, Antisocial Forces Exclusion Program, and Obayashi Group Anti-Bribery Program. Others are the Occupational Health and Safety Manual and Quality Manual.

2    Training to establish corporate ethics
In April of each year, workplace corporate ethics training is held for all employees of Obayashi Corporation and main Group companies as well as follow-up e-learning sessions. Using a textbook produced by the Corporate Ethics Promotion Committee, the training focuses discussion on specific cases, such as compliance with the Construction Industry Act and exclusion of antisocial forces, anti-bribery, preventing insider trading and the like.
We also have trainings for officers, employees working overseas, conducting education and training programs in accordance with the laws, regulations, and regional characteristics of each country. Group companies provide training based on the text used by Obayashi with the necessary revisions to the content according to the characteristics of the business areas in which each company operates.

3    Structure to disseminate corporate ethics, measure the extent of adherence to them, and assess their efficacy
We monitor the implementation of our corporate ethics programs, including the Bid-Rigging Monitoring.Program conducted by the Audit Committee and monitoring of internal audits by the Business Administration Department.
In order to incorporate assessments from independent parties, Corporate Ethics Committee's members include a corporate attorney, outside authority and the head of the employees' union. Group companies have also established similar committees, and systems are in place for promoting corporate ethics.

Others

Based on our Corporate Ethics Program, we have set forth and abide by rules and manuals for individual aspects of corporate ethics practice.

  • Antimonopoly Act Compliance Program
  • Antisocial Forces Exclusion Program
  • Obayashi Group Anti-Bribery Program
  • Anti-bribery due diligence related to public official or related party (including facilitation payment matters)
  • Sexual Harassment Prevention Guidelines
  • Information Asset Security Policy and Privacy Policy
  • Rules for the Preventing Insider Trading
  • Human Resources related rules and regulations