Preserve Corporate Value by Enhancing Internal Systems and Further Entrench Mission Statement

The ANA Group is taking steps to minimize exposure to legal risks and prevent incidents that could diminish corporate value.

Compliance Implementation Structure

The ANA Group has developed a compliance system based on the ANA Group Compliance Regulations to promote compliance with laws, regulations, and other standards related to business activities. CPLs are the driving force behind creating stronger awareness of compliance across the ANA Group. CPLs have been assigned to each of the Group’s companies under theGroup CSR / Risk Management / Compliance Committee, which serves in an advisory function to the board of directors.

Major Initiatives

Legal Compliance Education

The Group has created an educational handbook and e-learning course for anti-bribery laws around the world based on the ANA Group Anti-Bribery Rules. Our education is designed to prevent incidents that could degrade corporate value. Here, the personnel at Legal & Insurance conduct education in Japanese and English at our overseas offices in conjunction with education about competition laws, minimize legal risks on a global level. Further, the ANA Group seeks to bolster compliance structures across the entire group. To this end, we ensure clear establishment of points of contact between Group companies and Legal & Insurance, enabling easy two-way communication. We provide ongoing education for the group related to a variety of laws and regulations (including those covering air transportation businesses), the Anti-Monopoly Act, and the Labor Standards Act.

Seminars

Seminars are conducted periodically by Legal & Insurance to enhance the legal knowledge of employees and officers on laws and regulations related to air transport, contracts, and labor affairs. Further, Legal & Insurance holds dispatch seminars at Group companies, with content adjusted to meet the specific needs of the participants.

Seminar in Japan

Coordination with Overseas Branches

The Company has clearly identified venues for communicating between the Legal & Insurance and overseas branches and is stepping up measures to minimize exposure to legal risks on a global level and prevent occurrences that could diminish corporate value. Furthermore, the Company seeks to foster a mind-set focused on legal compliance among all Group executives and employees, including those working overseas. To this end, we hold legal compliance seminars at overseas branches.

Internal Reporting System

Founded on the ANA Group Rules for Handling Internal Reporting, we have established a point of contact (ANA Alert) for internal and external reporting (external law firms, entrusted overseas report reception teams). Our efforts here are to grasp compliance-related information and resolve issues. These reporting systems are available to all group executives, employees, and temporary personnel involved in operations. The ANA Group retirees and officers and employees of our business partners may also use these reporting systems. We protect the privacy of the caller and other relevant parties, and the Group assures that no punitive measures will be taken against those that seek consultation or cooperate in confirming facts. In the interest of bolstering this function, we also provide education and dissemination of information to the group, improve survey methods, and share information about our activities with Audit & Supervisory Board members.

ANA Alert Poster (in Workplaces)

Group Companies Compliance Survey

Investigations of circumstances surrounding compliance at Group companies are conducted once each year. These investigations consist of self-checks on the degree to which compliance was practiced with regard to relevant laws and regulations as well as examinations of issues pertaining to each Group company and to the entire Group. We conduct follow-ups with each company based on survey results as necessary in the interest of resolving issues.

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