Anti-Corruption
Anti-Corruption Policy
1. Basic Policy
Tokyu Corporation (the “Company”) and its consolidated subsidiaries prohibit any and all so-called corrupt acts that abuse personal or a third party’s authority or position in the course of duty, such as bribery (*1), conflict of interest (*2), embezzlement, forcing others to give advantage, and bid-rigging, and do not approve corrupt acts related to business partners, etc. of the Company and its consolidated subsidiaries.
2. Initiatives to prevent corrupt acts
With a view to preventing corrupt acts, we at the Company and its consolidated subsidiaries focus our efforts on the following initiatives and report on the status of the initiatives to the Board of Directors of the Company on a periodic basis.
We also require our business partners, etc. to carry out the same initiatives to prevent corrupt acts.
(1) Compliance with laws and regulations
We understand and observe the Unfair Competition Prevention Act and other relevant laws and regulations in Japan as well as relevant laws and regulations of the countries in which we operate our business.
Moreover, with an understanding of the aims of the National Public Service Ethics Act and other laws and regulations, we strive to prevent any violation of the said laws and regulations and proactively cooperate with investigation authorities in an emergency.
(2) Appropriate record keeping and retainment of records about gifts, entertainment, etc.
To demonstrate that all officers and employees of the Company and its consolidated subsidiaries do not give or receive gifts, entertainment, etc. beyond the scope of socially accepted norms, we make sure to keep appropriate records in accordance with accounting rules and control evidence based on risk evaluation. Gifts, entertainment, etc. relating to business partners, etc. that are not recognized in financial statements are also required to be reported in an appropriate manner and records are retained on a company basis. The reported contents are summarized and periodically reported to the Board of Directors in accordance with the basic policy for our internal control systems.
(3) Enhancement of dissemination and enlightenment activities
We ensure that all officers and employees of the Company and its consolidated subsidiaries(*3)are familiar with this Policy and related rules by making the information available for viewing in employee handbooks, Intranet, etc. at any time and promote initiatives to deepen their understanding, including regular training sessions.
By posting the Policy on the Company’s webpage and provide relevant information to business partners, etc. of the Company and its consolidated subsidiaries, we also work to gain understanding of our stakeholders about this Policy.
(4) Reporting of a suspected violation
If there is a potential violation of or if any questions arise about the Policy, relevant rules, laws, regulations, etc., we canvass widely for reports using consultation frameworks such as internal whistleblowing systems(*4)and customer service centers. When reports are received, we verify the real nature of the situation in good faith and implement necessary corrective actions.
(5) Action for dealing with violations, etc.
When an officer or an employee of the Company and its consolidated subsidiaries has violated this Policy, we will take strict actions against the said person in accordance with internal rules, etc. of the entity to which the said person belongs. Moreover, when an advisor, consultant, agent, subcontractor, etc. appointed by the Company and its consolidated subsidiaries has violated this Policy, we will also take strict actions against said person.
When the said violation is identified, we report to the Board of Directors in accordance with the basic policy on our internal control systems.
- (*1) Offering to or receiving from a person gifts, loan, reward, compensation, or other advantages as an incentive to draw fraudulent or illegal acts, aggravated breach of trust, etc. in the conduct of business beyond the limits of laws and regulations or the scope of social norms. We will not approve so-called facilitation payments if such payments are in violation of laws, regulations, etc., regardless of the amount of payment.
- (*2) Acts conducted by a person on a private basis and in an inappropriate manner to gain own benefits in conflict with the interest of the entity to which the person belongs (officer, employee, or others).
- (*3) Employees as used in this Policy include non-regular staff, contract employees, temporary workers, and other workers with different types of employment status.
- (*4) Internal whistleblowing systems of the Company and its consolidated subsidiaries are operated based on the provisions of the Whistle-Blower Protection Act and take into consideration the safety and protection of whistleblowers, by means such as the prohibition of any conduct that may disadvantage whistleblowers and the acceptance of anonymity.
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