Compliance
Maintain Corporate Value by Enhancing Internal Systems and Further Instill Our Mission Statement.
Basic Approach
It is essential that we comply with laws and regulations to ensure our ongoing existence as a corporation. We define "compliance" not only as following laws and regulations, notifications and instructions issued based on such laws and regulations, and the internal rules and standards of each ANA Group company, but also as complying with the aims and objectives thereof (including social demands, social consensus, and social ethics). ANA Group has established the "ANA Group Code of Conduct (Responsibility to Society)" to be followed by all officers and employees, recognizing that compliance occupies an important position in corporate management.
Compliance Implementation Structure
The ANA Group has developed a compliance structure based on the ANA Group Compliance Regulations to promote compliance with laws, regulations, and other standards related to business activities. The Group ESG Management Promotion Committee, an advisory body under the supervision of the Board of Directors, monitors the progress of measures related to the promotion of ESG management across the entire Group, with important matters being submitted to the Board of Directors. Under the Group ESG management promotion, each ANA Group company appoints an ESG Promotion Officer (EPO) as the person responsible for promoting compliance, and an ESG Promotion Leader (EPL) as a key driver of compliance at each workplace. These officers and leaders strive to strengthen awareness of compliance across the entire Group.
Major Initiatives
Anti-Bribery Policy
With regard to anti-bribery measures, we have established the ANA Group Anti-Bribery Rules in order to comply with the anti-bribery laws of each country, and have put in place a system to minimize legal risks on a global level and prevent situations that may decline our corporate value. At the same time, we have established provisions on how to respond when a violation is discovered. In addition, the ANA Group ensures thorough efforts to prevent bribery and corruption through its agreements and contracts with business partners.
Legal Compliance Education
We conduct a variety of educational programs for every Group executive and employee to acquire correct knowledge of various laws and regulations and to act properly based on appropriate judgment. We hold regular seminars on contract practices, labor practices, and laws and regulations related to air transportation, improving our business-essential knowledge. Seminars on competition law and air transportation are also held for Group executives and employees working overseas, focusing on minimizing legal risks globally. At the same time, we conduct tailor-made seminars with topics and contents adjusted to reflect the needs of each Group company and/or department at any time, aiming to foster a legal mind in the entire Group. In addition to enhancing online seminars, we maintain a global learning environment for Group executives and employees to learn about various laws and regulations of anywhere in the world by providing educational materials and explanatory videos on our compliance website, available on the corporate intranet.
Information Dissemination
Our compliance website includes the code of conduct that outlines the actions to be commonly followed by all Group executives and employees, specifically explaining employee do’s and don’ts, and provides educational materials for in-house training. The website also features manuals and guidelines on various laws and regulations, providing an environment where Group executives and employees can review such information at any time. In addition, we have established a mechanism that allows Group executives and employees to easily submit questions on legal issues from the website, thereby supporting them in making appropriate decisions in compliance with laws and regulations. Furthermore, we timely provide information on topics such as legal amendment updates and key points in labor and contract practices.

Initiatives to Prevent Harassment
We provide various training and education programs to prevent and raise awareness of workplace harassment, including training for newly appointed managers. In response to requests from each Group company, we conduct practical training designed for participants to concretely consider the risks of harassment hidden in each workplace and the appropriate measures to address them, as well as e-learning programs for all Group executives and employees. Aiming to create a workplace environment of "Goson" (mutual respect) where everyone respects each other and can exchange opinions frankly with peace of mind, we strive to foster a more comfortable work environment throughout the entire group with zero tolerance for harassment.
Compliance Survey of Group Companies
The annual survey takes place in all Group companies, which consists of self-evaluations on compliance with relevant laws and regulations to extract and assess issues pertaining to each Group company and to the entire Group. Following the review of the survey results, we conduct individual follow-ups with companies where issues are identified in order to achieve effective resolution and to strengthen ANA Group compliance structure.
Strengthening Cooperation with Group Companies
To strengthen the compliance system across the entire Group, we have clarified the points of contact between our Legal & Insurance Department and Group companies, building and operating close, two-way communication.
Internal Reporting System
Based on the "ANA Group Internal Reporting Handling Regulations," we have set up an independent and neutral point of contact (ANA Alert) both inside and outside of the Group (at a law firm) to ensure the early identification of compliance-related information within the Group and resolve any issues. All executives and employees (including temporary personnel) involved in ANA Group operations, retirees, and officers and employees of business partners can use these contacts of ANA Alert anonymously. All information reported to ANA Alert is handled with the utmost confidentiality, and the privacy of the whistleblower and relevant parties is strictly protected. We prohibit any disadvantageous treatment as a result of making a report or cooperating in the verification of facts. If any retaliatory action is confirmed, strict and resolute disciplinary measures will be taken, regardless of the reasons. Additionally, during ESG Promotion Month, we continuously conduct training for the familiarization of the internal reporting system. In fiscal 2025, there were 277 reports within the Group, and the system has spread throughout the Group as a reliable and effective system.

Cases of Compliance Violations
If a compliance violation is discovered, we take strict measures, such as disciplinary action, in accordance with the rules and regulations including employment regulations of each Group company. At the same time, we thoroughly investigate the root cause of the incident and implement specific preventive measures, thereby striving to build a structure that prevents the recurrence of similar incidents and to thoroughly reinforce compliance awareness across the entire Group.
Internal Audit
The ANA Group Audit Department conducts internal audits for the purpose of evaluating the Group's business operations in its management, operations, and performance, based on legal, rational, and ethical perspectives. We also audit and evaluate promotion structure and operational statuses of each company and department to ensure compliance.