Establishing a Global Compliance Framework

「The Company held individual discussions with the subcontractors covered by the recommendation and provided monetary remediation by making the necessary payments during the fiscal year. In addition, as measures to prevent recurrence, it provided all employees with training on the Subcontract Act and reviewed its internal regulations and operating rules. The Company compiled these improvement measures and recurrence-prevention measures, submitted an improvement report to the Japan Fair Trade Commission on 25 March 2026, and received the Commission's approval.」

「As of 31 March 2022, all 67 specific measures to prevent recurrence had been completed, and the Company continues efforts to maintain and embed them.」

「During the second quarter of the current fiscal year, Kayaba System Machinery Co., Ltd., formerly a consolidated subsidiary of the Company, ceased to exist as a result of an absorption-type merger in which the Company was the surviving company, and was therefore excluded from the scope of consolidation.」

「Following inappropriate conduct in inspection processes and other areas involving seismic-isolation and vibration-control oil dampers at the Company and its subsidiary KSM, the Company is promoting a group reorganisation aimed at compliance-based management as a measure to prevent recurrence, with the goal of eliminating the concentration of personnel identified as a cause of the misconduct and deficiencies in group governance. As progress has been made toward bringing the seismic-isolation and vibration-control oil dampers into compliance, the Company will carry out this merger as the final measure to prevent recurrence, seeking to promote personnel rotation, strengthen the governance framework and reduce misconduct risk.」

「As of 31 March 2021, 63 of the 67 specific measures to prevent recurrence had been completed, and the Company continues efforts to complete all measures.」

「We have taken seriously the recommendations for measures to prevent recurrence made by the external investigation committee and have formulated the following measures, which we will implement thoroughly and continue: (1) fostering a strict awareness of standards and reforming the corporate culture, including ① establishing compliance-based management and ② reforming the awareness of each officer and employee; (2) reviewing business viability assessments, business operations and information-sharing systems, including ① a well-balanced business operations framework, ② thorough implementation of personnel rotation and ③ development of systems for gathering and providing feedback on information; (3) improving inspection systems and methods, including ① improving the inspection framework and ② measures to prevent misconduct in inspections; and (4) strengthening internal audit and control systems, including ① strengthening the internal quality audit framework and ② strengthening the subsidiary management framework.」

「To enhance the effectiveness of the internal control system, we will work to establish and properly operate global compliance and internal whistleblowing systems, and strengthen our response to the Corporate Governance Code.」

「To enhance the effectiveness of the internal control system, we will work to establish and properly operate global compliance and internal whistleblowing systems, and strengthen our response to the Corporate Governance Code.」

「Establish a CSR headquarters and further enhance the effectiveness of the internal control system.」

「Establish a CSR headquarters and further enhance the effectiveness of the internal control system.」

「Establish a CSR headquarters and further enhance the effectiveness of the internal control system.」

「Establish a CSR headquarters and further enhance the effectiveness of the internal control system.」

「The Company has established a Code of Corporate Conduct as rules that directors and employees must observe when conducting corporate activities, and is working to ensure compliance with laws and regulations and establish corporate ethics. It has also established an internal whistleblowing system covering all group companies, including an immediate-reporting channel and suggestion box, and, following the enforcement of the Whistleblower Protection Act, has established dedicated reporting and consultation contact points.」

「The Company has established a Code of Corporate Conduct as rules that directors and employees must observe when conducting corporate activities, and is working to ensure compliance with laws and regulations and establish corporate ethics. It has also established an internal whistleblowing system covering all group companies, including an immediate-reporting channel and suggestion box, and, following the enforcement of the Whistleblower Protection Act, has established dedicated reporting and consultation contact points.」

「The Company has established a Code of Corporate Conduct as rules that directors and employees must observe when conducting corporate activities, and is working to ensure compliance with laws and regulations and establish corporate ethics. It has also established an internal whistleblowing system covering all group companies, including an immediate-reporting channel and suggestion box, and, following the enforcement of the Whistleblower Protection Act, has established dedicated reporting and consultation contact points.」

「Establishment of a global compliance framework 1. Establishment of a Compliance Promotion Office and development of the compliance organisation and framework 2. Introduction of an internal leniency programme 3. Strengthening and thorough implementation of compliance training」