Compliance

Our basic approach

SMS Group, as a part of society, recognize that it is extremely important to conduct business with integrity and fairness. We have established the "SMS Business Guidelines" to comply with laws, regulations, and social norms related to a wide range of our business domains, and conduct training to ensure that all officers and employees are familiar with the Guidelines. In addition to complying with laws and regulations, the Guidelines set forth the code of conduct to operate businesses based on high ethical standards in light of social conventions and morals to ensure that misconduct is thoroughly prevented.

Our overseas subsidiary, MIMS, has also established the "MIMS Code of Business Conduct," which is applied to all employees of MIMS as well as agents and other external partners.

Promotion system

The Risk Management Department oversees compliance measures for the entire Group on a cross-organizational basis, while the Internal Audit Department conducts audits on compliance with laws and regulations, nurturing an ethical awareness, and the status of Group-wide risk management.

Anti-corruption initiatives

The SMS Business Guidelines state that we shall conduct our business activities in accordance with economic and market principles, and prohibit the provision of improper benefits to public officials and business partners and the receipt of improper benefits from these stakeholders.

MIMS has established the "Anti-Bribery Policy" to prevent corruption. To ensure compliance with all relevant laws and regulations in all countries and regions in which MIMS operates as well as the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act (UKBA), MIMS disseminates information and conducts necessary training within the company, and implements appropriate due diligence when engaging in transactions with third parties.

Apart from membership fees for trade associations, we do not make any contributions to political campaigns, candidates for public officials, political parties, other political organizations, lobbying activities, trade associations, tax-exempt groups or other groups whose role is to influence political campaigns or legislative activities.

Expenditures to trade associations and political organizations by SMS Co., Ltd.

Note: The purpose of membership fees for trade associations is to collect information related to the business.

Protection of consumer interests

We strive to present accurate and easy-to-understand information that does not mislead users with regard to our services. We have established a prior confirmation system to eliminate false and exaggerated expressions from our websites and advertisements, and to use appropriate expressions that do not constitute social discrimination or human rights violations.

We have also established an inquiry desk to receive requests and inquiries from service users. We will respond sincerely to such requests and inquiries and utilize them in our future business activities.

Prevention of unfair competition

The SMS Business Guidelines clearly state that we will strive to ensure that our business activities do not interfere with the promotion of fair and free competition. We prohibit unfair slander and defamation of competitors and their products and services. We also prohibit service price agreements with competitors and an unreasonable restraint of customers from doing business with competitors.

Elimination of antisocial forces

We are firmly committed to preventing any relationship with antisocial forces that threatens the order and safety of civil society. We are working to strengthen our system for eliminating antisocial forces in cooperation with related organizations as a member of the Tokuboren (the Metropolitan area violation prevention association). When starting new business transactions, the Group strictly checks business partners and strives to prevent transactions with antisocial forces by including provisions regarding the elimination of antisocial forces in contracts, etc.

Proper tax payment

We continue to grow and contribute to society as an everlasting corporate group, while fulfilling our corporate social responsibility through appropriate tax payments by complying with the tax-related laws and regulations and respecting the spirit of them in each country and region where we operate business.
From the viewpoint of maximizing shareholder value, we strive to appropriately and effectively utilize preferential tax treatment. However, we do not engage in tax saving through interpretation or application that deviates from the purport of laws and regulations, rules, etc., or through intentional tax avoidance such as by establishing dummy companies with no business purpose.

Regarding tax risks associated with international transactions, we request advice and guidance from experts as necessary. In particular, the transfer pricing taxation and CFC (Controlled Foreign Company) rules will be dealt with as follows.

- Transfer pricing taxation
The transaction price applicable to foreign affiliated transactions shall be calculated in accordance with the arm's length principle, based on the laws and regulations of each country and region and the Transfer Pricing Guidelines issued by OECD (the Organisation for Economic Co-operation and Development).
The price calculation method shall be appropriately documented in cases where it is required under the laws and regulations of each country or region, or where it is necessary due to the size of transactions and tax risks.

- CFC (Controlled Foreign Company) rules
We do not use lightly taxed countries for tax avoidance. When investing in lightly taxed countries for business reasons, we pay taxes appropriately in accordance with the laws and regulations of each country or region.

We will build a sound relationship with the tax authorities of each country and region by providing appropriate information in response to their requests. In addition, if there is a difference of opinion with the tax authorities of each country, we will strive to resolve it through constructive dialogue.

Establishment of whistle-blowing hotlines

We have introduced a whistle-blowing hotline where all officers and employees can report and consult on violations of laws, regulations, and internal rules as well as harassment in the workplace. We also have an external hotline managed by outside lawyers in case a whistle-blower feels uncomfortable about reporting to the internal hotline.
The whistle-blowing hotlines allow officers and employees to choose freely whether to report anonymously or not. We ensure the confidentiality of information related to whistle-blowing. We also ensure that whistle-blowers will not suffer any disadvantages, including retaliatory personnel action, due to the content of the report. In the external hotline, whistle-blowers can access a female contact person.

MIMS has established procedures for internal reporting and ensures that employees are free to choose whether to report anonymously or not, and that they will not suffer any disadvantages by the reporting.