Compliance

We set our expectations and guidelines for employee behavior in the Basic Principles of How to Work that were first established in 1982 by our company founder, Yo Sato. What started as a list of "things to bear in mind in daily work, based on personal experiences" he gained from the earlier days of his career underwent revisions over the years to become the thirty-five articles in use today. When our second company president, Tokuo Fujita, wrote our employee handbook "The Spirit of SATO," he dedicated a chapter to these basic principles while adding new contents on our management policies/ideas and corporate culture.

This handbook provides an easy-to-understand account of the "right" things to do in reality-based scenarios, and is used to foster compliance awareness in our employees.

All employees and senior management of our group will comply with business practice standards and applicable laws worldwide to not give or offer bribes directly or indirectly in any form, monetary or otherwise.

We comply with laws and regulations related to political donations in each country. We do not make donations, offer funding or provide favors to politicians or political organizations in any country in a way which may be deemed to be socially unacceptable.

We comply with antitrust laws in various countries and regions that aim to ensure fair competition.

1. We will not exchange with competitors information that is competitively sensitive in terms of aiding price fixing, production control or market sharing.
2. We will not impose resale price maintenance and other anti-competitive restrictions on distributors and resellers.

Introduced in 1976, Teiho is SATO's very own system that lets all employees submit short, regular reports (written within a set word count) directly to the management to participate in the running of the company. Through Teiho, new ideas that employees derive from daily work or feedback they gather from interactions with customers can be incorporated quickly into decision-making at the top level. Teiho encourages input — even the negative ones — from our business front lines and customer touch points, serving as a form of monitoring to prevent any blind spots that could lead on to crises.

The Teiho system is an important pillar for building our corporate culture around compliance.

We have established whistleblowing standards/procedures for employees in Japan to report any suspected violation of laws and regulations internally or via an external platform that is managed by an independent third party. We also have in place a whistleblowing policy that allows for employees of our overseas subsidiaries to escalate their concerns via a communication channel set up by the company. These help us detect possible compliance breaches and take preventive actions early.

We have a framework for internal controls based on our basic policy approved by the board of directors to help us instill our corporate values and ensure proper business operations.

We aspire to solve challenges and create new value for customers worldwide operating in diverse working environments, industries and market sectors. It is important that proper internal control systems are established and consistently implemented for both frontline operations and organizational-level leadership to realize our corporate social responsibility and grow sustainably.

For example, the execution of duties by employees, directors and subsidiaries is controlled by corresponding management regulations that stipulate responsibilities and authority, and subject to regular audits by our Internal Audit Department which reports directly to the Group CEO. With the support of the board of directors, we will continue to review our set of internal controls and test them regularly to ensure relevance and efficiency.