Continuing to review and strengthen the system to prevent insider trading and providing training for employees
As a specialist company that supports corporate disclosure and IR, PRONEXUS implements a wide range of measures to strengthen insider information security, from organizational and personnel structures to setting dedicated areas and establishing information systems.
Within the Company, the Insider & Information Security Committee plays a central role, ensuring that employees comply with the rules on handling of insider information and prevention of insider trading.
Twice a year, all employees attend a training session on preventing insider trading that includes the latest cases and they are tested on their understanding via e-learning. New employees and mid-career employees receive their own training. In addition, sales staff, who often come into contact with confidential information, as well as employees responsible for handling insider information, take a further five sessions of specialized training every year. Moreover, we conduct regular training as well as onsite surveys at Group companies, associate companies and outsourcing suppliers.
Our stock transaction regulations completely prohibit managers at the division head level and higher, as well as sales staff and those who handle insider information, from dealing in the shares of listed companies. For other employees, we have a permission system, which requires them to apply in advance before dealing in shares.
Every year, all employees are required to hand in a written pledge to prevent insider trading.
We appropriately monitor the status of compliance in these matters and work to make improvements and enhancements.
Creating a framework to prevent compliance risk from materializing and to ensure early detection
Companywide compliance risk management is led by Compliance and Quality Management Division, which has created rules and compliance manuals based on the PRONEXUS Internal Control System Basic Policy. The compliance manual is updated regularly to incorporate case studies that touch on new themes, such as corporate misconduct, the spread of social media and work-style reforms. This serves to enhance its practicality.
In addition, a PRONEXUS Group Corporate Ethics Hotline has been set up to enable reporting related to corporate ethics. Cards with details on the hotline are distributed to employees and posters are placed throughout the company to increase awareness and to encourage use. A survey on compliance understanding is also given to all employees via an external agency to make sure everyone has an accurate understanding of the situation.
To manage risk related to personal information, we established a personal information protection policy that ensures the appropriate handling of personal information. As well, we are maintaining and managing a personal information protection management system. We conduct an onsite survey of information management systems among outsourcers who deal with particularly sensitive personal information.
Providing compliance training for employees
We have focused on compliance training, as with training on preventing insider trading. Twice a year, all employees attend a compliance training session, and they are tested on their understanding via e-learning. New employees and mid-career employees receive their own training.
Other compliance training includes training on subcontracting laws for employees in divisions placing orders (once a year), training on sales and legal affairs (twice a year), and training on copyright for employees in sales and planning/production divisions.