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

Based on the ANA Group Compliance Regulations, the ANA Group promotes compliance initiatives with laws and regulations as well as other standards in its business activities. CSR Promotion Leaders are the driving force behind this compliance promotion system.
In addition, the Company has secured clearly identified venues with the Legal & Insurance Department and group companies in order to establish a system that facilitates mutual communication.

Major Initiatives

Compliance with Various Laws

The Group must conduct fair competition and transactions in accordance with various laws and regulations related to sales and marketing and various other areas. Accordingly, the Company provides seminars on the Act Against Unjustifiable Premiums and Misleading Representations, the Act Against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, and contract affairs to help compliance staff master the appropriate knowledge.
At the same time, the Company conducts training and awareness-raising activities with regard to a range of laws and regulations that include legislation related to air transport and labor laws. These activities include holding seminars and issuing email magazines for group companies.

Fair Trade Initiatives

The Group recognizes the serious risks that may materialize in the event of a violation of competition or anti-bribery laws of the countries in which we operate, and we have implemented measures to address these risks. We have established the ANA Group Rules for Competition Law Compliance and the ANA Group Anti-Bribery Rules as internal rules for the Group. We distribute a handbook that provides commentary on these rules using specific case studies to relevant departments. We also provide regular education and e-learning programs for relevant managers.

Protection of Intellectual Property

The ANA Group works to upgrade system to protect and use intellectual property, as well as for respecting the intellectual property rights of other companies and preventing infringement.
We have clearly identified a contact point within the Group to provide consultation and support on matters related to intellectual property to all group executives and staff.

Coordination with Overseas Branches

The Company has clearly identified venues for communicating between the Legal & Insurance Department 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.

Implementation of Internal Reporting System

We have established the ANA Group Rules for Handling Internal Reporting as a subordinate rule under the ANA Group Compliance Regulations. In addition to an internal contact point for reporting, we have also implemented a system to identify management risk by outsourcing reporting system processes to an external law firm.We are also developing an outsourced contact point to receive information in English for reports originating overseas. These reporting systems are available to all group executives, employees, and temporary personnel involved in operations. 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.
We publicize these reporting systems via posters displayed on group premises, as well as through a dedicated website on the group intranet.

Major Initiatives in Fiscal 2017

On-Site Seminars at Group Companies
Held 48 seminars at 23 group companies
Our Legal & Insurance Department travels to group companies providing seminars tailored to the requests of each. The seminars provide for better understanding in a more conductive environment.
During fiscal 2017, we saw an increase in demand for seminars, particularly in the area of labor law. A total of 1,868 people attended the seminars, representing a two-fold increase compared to the prior year.
Number of On-Site Seminar Participants 1,868 Labor Law 1,210 Competition Law 268 Air Transportation Law 353 Contract Law and Practice 37
Competition Law and Anti-Bribery Law Seminars at Overseas Branches
Held 7 seminars at overseas branches
Seminars were held at overseas branches of the ANA Group on competition and anti-bribery laws in light of the recent trend toward stricter enforcement by the authorities in each country to prevent unfair competition.
These seminars employed case studies that presented situations similar to those found at each business site based on the ANA Group Cartel Prevention Handbook and the ANA Group Anti-Bribery Handbook.
Seminar at an overseas branch
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. In fiscal 2017, the Group added work hour management as a category in our compliance survey. While survey results were generally favorable, we performed follow-up on corrective measures as necessary, working towards the resolution of issues identified.

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