Compliance

Compliance system

For the purposes of developing and establishing a compliance system for the Medley Group, Medley has created compliance regulations and a Legal Compliance Department to promote a variety of internal compliance systems. In addition, owing to the importance of compliance in the field of medical health care, as is common among overseas companies, we have also established the position of General Counsel to be in charge of legal compliance functions and we are working to ensure full compliance throughout the decision-making processes of our corporate group.

The Legal Compliance Department, headed by General Counsel, implements measures necessary to establish a compliance system for the entire corporate group and, by regularly conducting compliance training necessary to the business activities of each department, a system to ensure that business activities are conducted with high ethical standards while collecting compliance-related information has been established.

The Legal Compliance Department provides reports on compliance-related activities at management meetings once per month and to the Board of Directors once per year.

Compliance training

All Medley employees (including part-time, temporary, and seconded employees) receive training in corporate ethics and basic compliance as well as insider trading prevention when they enter the company or when their contracted employment period begins. We work to have all employees adopt a mindset regarding compliance that ensures that they not only comply with laws and regulations, but correctly understand societal norms and conduct corporate activities in a way that conforms with them.

We have implemented continuous training for all employees covering topics including legal compliance, corporate governance, general contract theory, and intellectual property law in order to raise and maintain the level of compliance knowledge on a companywide level.

Establishment of internal reporting system

Based on internal reporting regulations, Medley has established an internal reporting system to allow the reporting of internal misconduct. The company has established a total of three internal and external three reporting routes (contact points) including reporting to the compliance department, reporting to a standing corporate auditor, and reporting to an external legal firm.

The privacy of those reporting or consulting via these contact points is strictly protected and rules have been established to ensure that those reporting or consulting do not suffer any disadvantage.