Decision-making Structure for Investment Management/Compliance System
Management Structure
Decision-making Structure for Investment Management
"HHRAM establishes Regulations for Asset Management and asset management guidelines, and set forth basic approaches to investment management, including investment policy, rules on conflict-of-interest transactions, and disclosure policy.
Furthermore, HHRAM establishes asset management plans in accordance with these guidelines, and make decisions on acquisitions and other matters concerning asset management according to the investment policy and rules on conflict-of-interest transactions set forth in the guidelines."
Decision-making flow
Compliance System
HHR and HHRAM build robust compliance and internal audit systems by systematically ensuring multiple check functions based on Basic Policies Concerning Compliance.
Any conflict-of-interest transactions which meet certain standards shall be approved at an Executive Meeting of HHR.
Compliance training
HHRAM invites outside lecturers to conduct training targeting all of its officers and employees with the purpose of having them observe compliance and developing an awareness. In addition, training for managers and transferees is also provided by in-house lecturers in a timely manner.
Major themes provided by outside lecturers
・Customer-oriented business conduct
・Conflict-of-interest transactions
・Insider trading regulations
Risk monitoring
HHRAM strives to enable accurate prevention activities for various risks surrounding business and appropriate response activities for crises when risks become apparent based on the risk management regulations and risk management manuals established by HHRAM
Efforts to prevent corrupt practices
HHRAM has been working to prevent corruption based upon the Anti-Corruption Policy stipulated by Hankyu Hanshin Holdings, Inc., our parent company. (The below is excerpted from the website of Hankyu Hanshin Holdings, Inc.)
Anti-Corruption Policy
1. Preventing Bribery and Other Corrupt Practices
All officers and employees of Hankyu Hanshin Holdings Group shall comply with all applicable laws in force in the countries where they operate and shall work to prevent corrupt practices. As used here, “corrupt practices” means practices in which officers or employees abuse the power entrusted to them to gain an illicit advantage or to commit an act that is contrary to law or ethical standards. Examples of corrupt practices include bribery, unfair trade practices (including abusing a superior bargaining position to exploit a weaker party), and insider trading. Officers and employees of Hankyu Hanshin Holdings Group shall observe the following anti-bribery rules:
- All officers and employees of Hankyu Hanshin Holdings Group shall on no account give, offer, or promise any money, privilege, hospitality, objects of value, or any other benefit or advantage to public officials, whether directly or indirectly. As used here, “public officials” includes persons who serve a role analogous to that of a public official. Additionally, officers and employees shall on no account accept any privilege, hospitality, objects of value, or any other benefit or advantage beyond that which can be justified as business practice or within social norms.
- Whenever officers or employees of Hankyu Hanshin Holdings Group pay money to public officials, they shall accurately record the payment and properly manage the record.
2. Organizational Support for Combatting Corrupt Practices
Hankyu Hanshin Holdings Group shall provide training to ensure that its officers and employees fully understand this policy. Member organizations of the Hankyu Hanshin Holdings Group shall provide anticorruption guidelines that are relevant to their business profile.
3. Organizational Response to Corrupt Practices
Hankyu Hanshin Holdings Group shall provide information about, and facilitate the use of, the Corporate Ethics Consultation Desk, a means by which any of the Group’s officers or employees, or any trading partners or other interested parties, can swiftly report any violations or suspected violations. The Group shall address any reports swiftly and effectively.
Effective March 1, 2022
Hankyu Hanshin Holdings, Inc.