Obayashi Group Corporate Ethics Consultation and Reporting System

We have established Obayashi Group Corporate Ethics Consultation and Reporting System not only to prevent all illegal acts, but also to detect and correct violations of laws and illegal acts in the early stages. We strive to manage compliance and crisis risks in the entire Obayashi Group.

Whistleblowers, Reporting Methods, Investigation Methods

If there are frauds or suspects related to the Group's business, we accept reports even without an evidence. Even when the subject of the report is our officer. We will not ignore the voice of the whistleblowers. However, we do not accept reports made for the purpose of personal benefit, defamation, slander or other misconduct.

Whistleblowers Hotlines are open for Obayashi Group employees, officers, seconded employees, employees accepted on assignment, part-time employees, suppliers, etc.
Hotlines and reporting methods Both internal and external contact points (a law firm) for reporting are available. In April 2019, a new contact point for reporting to Audit & Supervisory Board members was established. Reports are accepted by email, fax, document or by phone, and also, they can report anonymously.
Investigation firms Reports received are mainly led by the Secretariat of the Corporate Ethics Committee (Head Office General Administrative Department) or the Audit & Supervisory Board (when reported directly to the Audit & Supervisory Board), and investigations are conducted by requesting cooperation from related departments if necessary.
Results of Investigation After completing the investigation, whistleblowers are notified of the results of investigations.

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Protecting Whistleblowers

Obayashi Group companies, Obayashi Group officers and employees, etc. prioritize whistleblower's protection. Whistleblowers will not be dismissed or dealt with any disadvantages as a result of the report. Also, whom it received the reports as each contact point or related departments take care the whistleblowers who may be subject to disadvantageous handling are not to be specified.

Whistleblowers can request correction at the hotline desk if they receive unfavorable handling from the Obayashi Group companies and Obayashi Group officers or employees, etc. for the reason that they reported. The hotline desks are required to check the contents and correct any disadvantageous handling as necessary. In addition, the whistleblowers themselves must not disclose them as whistleblowers and the investigation results notified from the hotline desk to third parties.

In addition, the Obayashi Group's Corporate Ethics Reporting System Operation Rules clearly state that "hotline desks and related departments must take care not to identify the reporter so that the reporter will not suffer disadvantage".

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Informing Hotline Desks

In addition to posting the hotline desks on the company's intranet, posters that describe the hotlines are posted in places that are easily noticeable to officers and employees, such as business offices. We are striving to promote the use of the reporting system by making it known to all officers and employees through corporate ethics training.

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Reporting Cases and Results

The reporting system has established in FY2006. The contents of the report are diverse, including fraudulent accounting, and some of the cases were prevented before they developed into serious violations of laws. In order to further promote corporate ethics, examples of reports and results are disclosed.

Report Type Examples of Reports Results of Investigation and Examples of Actions Taken
Fraud An employee instructed subcontractors for a padded demand and embezzled the money. The fact was confirmed, and the employee was punished internally and requested for refund.
Harassment A project manager of the construction site forced to perform impossible tasks, and mentally attacked, such as uttering violent languages, when a person could not do them. The fact was confirmed, and the project manager of the construction site was transferred to prepare appropriate environment for the construction site.
Construction Problem An employee tried to correct the failure in construction without receiving approval from the supervision office. It was confirmed that the correction was made with the approval of the management office.
Labor Management Problem An employee gave instructions to conceal an accident. The fact was confirmed, and the employee was punished internally.
Others A subcontractor in the construction site forges construction permit. The fact was confirmed, corrective instructions were given to the subcontractor, and reports were made to various government agencies.

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