Compliance Framework
Compliance Basic Policy
ORIX Group has positioned compliance as one of our most important management issues, striving to build an effective compliance structure alongside a corporate culture that values high ethical standards, and good faith, fairness and transparency in all corporate activities.
Compliance Structure
ORIX Group reports important compliance matters to the Executive Committee and the Audit Committee of the Board of Directors. The compliance department, under the oversight of the Executive Officer responsible for compliance, coordinates with the compliance officers appointed at subsidiaries and business units and promotes compliance activities across the Group.
Annual Compliance Plan
In order to prevent and mitigate compliance risks, ORIX Group establishes annual Group-wide compliance initiatives each fiscal year.
Each Group subsidiary and business unit conducts risk assessments pursuant to these compliance initiatives, and formulates an annual compliance plan for its own business in accordance with such risk assessments. The compliance department reviews the appropriateness and effectiveness of the individual annual compliance plans. Following such review, each annual compliance plan is then put into practice at each respective subsidiary or business unit.
At the end of the relevant period, a status report is filed and the content of this report is reviewed by the compliance department.
Efforts to Raise Compliance Awareness
At ORIX Group, members of senior management—including the CEO and Executive Officer responsible for compliance—regularly distribute messages to all Group officers and employees with the objective of enhancing and reinforcing compliance awareness. The compliance department regularly sends compliance-related information to comprehensively raise awareness among employees.
In order to promote understanding of the importance of compliance among ORIX Group employees and translate that awareness into day-to-day practices, compliance training is conducted annually by way of e-learning, group training and on-site courses. Additionally, multi-level and customized training courses are available for all employees, including new hires and managers.Training for managers incorporates specific examples of harassment and ways in which to address such situations.
The e-learning courses provided annually to the officers and employees of ORIX and its subsidiaries in Japan are based on the Code of Conduct, which are applicable to all Group employees, and focus on risks, laws, and regulations that require special attention. Specifically, the courses focus on anti-bribery and corruption, anti-money laundering and combating the financing of terrorism (including international sanctions compliance), insider trading, and conflicts of interest, and refers to actual incidents of compliance violations that have occurred.
In the fiscal year ended March 31, 2023, approximately 29,000 employees completed the e-learning courses.
As for ORIX’s overseas subsidiaries, training courses on the Code of Conduct are provided annually, and compliance training courses encompassing anti-bribery and corruption, anti-money laundering and combating the financing of terrorism (including international sanctions compliance), and other risks that require assessment and attention are also provided regularly.
In addition to trainings, employee surveys and workplace environment interviews are conducted to help raise compliance awareness among employees of ORIX Group.
Compliance Training
ORIX Group regularly holds Compliance Officer Liaison Meetings, which are attended by the compliance officers (officers and managers appointed to promote compliance at each Group subsidiary and business unit), and takes various actions to promote the understanding of ongoing compliance measures and improve overall knowledge regarding compliance.
In addition, personnel at the compliance department endeavor to build a library of the latest market practices and information related to compliance and acquire skills for implementing compliance by liaising with external organizations and undergoing external training courses.
Surveys and Monitoring
The compliance department conducts employee surveys on workplace environment and compliance awareness, and reflects the results of such surveys in compliance measures.
In addition, in the event of a potential compliance violation, the compliance department conducts an investigation, provides instructions on corrective actions, and provides recommendations to the Human Resources Department on disciplinary action to take against violators, as appropriate.
Internal Whistleblower System / External Whistleblower System
The ORIX Group has established an internal whistleblower system and an external whistleblower system.