Implementation of Recurrence Prevention Measures Following Fictitious Sales Recording and Misappropriation of Assets
First written in FY2020. 8 of 14 entries say "Advanced", first in FY2021. Latest entry: FY2026.
No other company in this theme has enough history to compare yet.
- FY2026AdvancedAnnual report
「The company takes seriously the findings and recommendations of the Special Investigation Committee concerning the receipt of employment adjustment subsidies and emergency employment stabilization subsidies, and is working to prevent recurrence. The company was also designated by the Tokyo Stock Exchange as a Security Administration Designated Issue on 22 November 2025 and is implementing various improvement measures based on the “Improvement Plan and Status Report” announced on 15 April 2026.」
The recurrence-prevention measures following the employment subsidy issue were made concrete as various improvement measures based on the Improvement Plan and Status Report. The company is advancing the recruitment and development of personnel supporting the internal management system, the use of external experts, committee operations and training for all employees. - FY2026-H1WorsenedAnnual report
「Although the company disclosed measures to prevent recurrence on 31 October 2025, the Tokyo Stock Exchange has determined that there remains a significant need to improve the company's internal management systems and related matters. Accordingly, the company's shares will be designated as a Special Alert issue.」
Even after the disclosure of measures to prevent recurrence, the Tokyo Stock Exchange indicated that it had determined that significant improvements were still needed in the company's internal management systems and related matters. In addition to implementing the existing measures to prevent recurrence, the company is now required to make further improvements involving an external review. - FY2025Move toward fundamental strengthening following the discovery of new misconductAnnual report
「In light of the inappropriate receipt of Go To Travel business benefits and inappropriate circular fund transactions related to those benefits, we have determined that fundamental changes in awareness of compliance and governance are necessary to correct the causes that led to the fraudulent receipt of employment adjustment subsidies. Taking into account the findings and recommendations of the Special Investigation Committee, we will steadily implement measures to prevent recurrence and work to strengthen our compliance framework.」
After the company implemented measures to prevent recurrence of the previous Go To Travel benefit issue, fraudulent receipt of employment adjustment subsidies was discovered. In addition to continuing its existing measures, the company committed to fundamentally changing its awareness and steadily implementing measures to prevent recurrence based on the recommendations of the Special Investigation Committee. - FY2024RestatedAnnual report
「Our group takes seriously the findings and recommendations of the investigation and verification committees composed of external experts concerning applications for Go To Travel business benefits, and is working to prevent recurrence so that the same thing never happens again.」
The company continues to prioritize measures to prevent recurrence following the Go To Travel benefit issue and rigorous operation of its internal control systems. - FY2023AdvancedAnnual report
「Since April 2023, we have held quarterly discussions focused on matters that newly arose during the current quarter, such as transactions involving credit limits of material amounts to be resolved by the Board of Directors and new transactions that differ in nature from past transactions.」
Following the reverification of the Go To Travel benefit issue, the company is developing and implementing specific measures to prevent recurrence, including clarifying management responsibility, establishing a nomination and compensation committee, improving the accounting literacy of senior management, limiting the CFO's responsibilities, strengthening coordination with the audit firm, and rigorously separating duties between the sales and corporate divisions. - FY2023-Q3Measures to prevent recurrence are being reformulated following reverificationAnnual report
「We take the results of this verification seriously and will formulate and steadily implement measures to prevent recurrence. We will announce the specific measures to prevent recurrence separately once they have been determined.」
Following the results of the reverification concerning applications for Go To Travel business benefits, the company indicated its policy of formulating and implementing measures to prevent recurrence. However, it stated that the specific details would be disclosed after they were determined, and this filing does not describe any new specific measures. - FY2022AdvancedAnnual report
「We reviewed and improved items and standards in multiple internal regulations, including the authority matrix under the Rules on Authority and Responsibilities, approval standards under the Credit Management Rules, and matters to be referred to the Risk and Compliance Committee under the Risk Management Rules. In addition, to foster an awareness that transactions should be abandoned where the necessary internal regulations and processes cannot be completed in time, we added a field requiring the final approver or the director of the department responsible for the matter to enter the transaction start date when approving an internal application, creating a system under which approval cannot be granted without entering the date.」
Following issues concerning applications for benefit payments, the company expanded its measures to prevent recurrence into specific operating procedures, including reviews of internal regulations, approval standards, and matters referred to the Risk Committee, mandatory date entry when approving internal applications, manuals for applying for benefits and subsidies, training, and compliance declarations. - FY2021AdvancedAnnual report
「We established a new section within the corporate division to issue invoices to corporate customers, manage gift certificates, and verify customer payments against reservation records, thereby improving our business processes. In addition, throughout all sections of the corporate division, we separated sales staff from booking and arrangement staff and developed an organizational structure in which operations cannot be completed solely by sales staff.」
Following the fictitious booking of sales and misappropriation of assets, the company established specialized sections for billing, gift certificate management, and payment verification, separated sales and booking and arrangement functions across all sections, established an external whistleblowing channel, and conducted training and an awareness survey for all employees. Measures to prevent recurrence have progressed from policy statements to the development of specific systems and structures. - FY2020First statedAnnual report
「To prevent recurrence, we formulated measures based on the following key initiatives, taking into account recommendations from the external investigation team, and are advancing these initiatives: 1. Improvement of business processes 2. Development of the organizational structure 3. Raising compliance awareness」
Following the misconduct, the company newly established and implemented specific measures to prevent recurrence, including ensuring the existence of transactions, strengthening controls over the acquisition of gift certificates, reconciling invoices with the reservation registration system, separating sales staff from booking and arrangement staff, expanding internal whistleblowing channels, and enhancing internal training.