Compliance

“Compliance” at SoftBank Corp. is not merely about complying with laws and regulations, but also about meeting society's higher ethical and moral expectations. All our senior executives and employees at SoftBank Corp. are obliged to comply with the Code of Conduct which sets out rules and responsibilities for all members.

SoftBank Code of Conduct

  1. Compliance Commitment

    We will maintain high ethical standards, observe all applicable laws, regulations and internal rules, and act in accordance with social norms, and in the event we become aware of any actual or possible breach of the foregoing, we will seek to resolve such breach by reporting to and consulting with our manager, or by using the compliance hotline.

  2. Respect for Human Rights and Prohibition of Discrimination and Harassment

    We respect human rights and will not tolerate discrimination or harassment based on race, ethnicity, religion, nationality, origin, gender, gender identity, sexual orientation, age, disability or disease, etc.

  3. Customer Satisfaction

    We will provide products and services that meet the needs of our customers as well as accurate information on those products and services. We will also respond appropriately to customers' opinions and comments.

  4. Commitment to Fair Business Practices

    We will conduct our business activities without engaging in anti-competitive conduct in the market and maintain fair and mutually viable relationships with our business partners.

  5. Appropriate Use and Management of Company Assets

    We will use and manage company assets in accordance with appropriate rules and not use them for personal gain or unlawful profit. Further, we will not engage in transactions that involve conflicts of interest without the prior approval from the company or that constitute insider trading.

  6. Promotion of a Mutually Pleasant and Comfortable Working Environment

    We will promote innovation throughout the company by recognizing and respecting each other's diversity, while respecting various working styles and striving to ensure a safe and healthy workplace and promote a pleasant and comfortable working environment for everyone.

  7. Social Contribution and Environmental Conservation

    We value resources and strive to preserve the global environment and are committed to contributing to society in a sustainable manner through the resolution of social issues in liaison with local communities.

  8. Respect for Intellectual Property Rights

    We recognize the importance of intellectual property rights, and will respect the intellectual property rights of others, and promote the appropriate protection and utilization of our own intellectual property rights.

  9. Protection of Information

    We value all information and data related to our customers, business partners and employees, and are committed to handling personal information and confidential information and other information assets in an appropriate manner and protecting them from security threats.

  10. Appropriate Relationship with Politics and Government

    We will maintain appropriate relationships with political and governmental officials and not be involved in corruption or unethical behavior such as providing or receiving inappropriate gifts or entertainment.

  11. No association with organized crime groups or criminal activities

    We will not have any involvement whatsoever with organized crime groups or criminal activities such as money laundering.

Compliance Structure

The Board of Directors of SoftBank Corp. maintains a corporate compliance structure led by the Chief Compliance Officer (CCO) who establishes and strengthens the internal compliance structure through various means and initiatives. The CCO is assisted by the Compliance Department whose members further liaise with Compliance Promoters and Representatives in each business unit to ensure that our day-to-day operations are compliant with all relevant laws and regulations as well as our corporate compliance policies.

All compliance violations including bribery and corruption as well as acts which may be a potential violation are regularly reported to the CCO. Apart from this, our CCO overlooks overall anti-bribery measures in place. Furthermore, these are regularly reported to the Board of Directors and the Audit & Supervisory Board.

SoftBank Corp. disseminated “SoftBank Code of Conduct” to all employees (including part-time employees) at our Group company as well as subsidiaries and affiliated companies, to encourage compliance with law and corporate ethics in their daily work. Compliance Handbook which contains laws and case studies is available on our intranet to help fellow employees better understand the Code of Conduct and implement the embedded principles into their day-to-day operation.

Compliance Hotline

In order to discover, ameliorate, or prevent compliance risks, including overall bribery and corruption in business activities, at an early stage, we have a “Compliance Hotline” for all executives, employees, suppliers of SoftBank Corp. and our subsidiaries to raise compliance violations or any potential issues. Consultations and reports are handled appropriately following a thorough investigation, and persons consulting with and reporting to the hotline are guaranteed not to be subject to any form of retaliation.

To make the “Compliance Hotline” easy to use, various reporting methods are available such as direct reports in person, by telephone, email, or postal mail. We also accept anonymous reports as well. Points of contact have been established both inside and outside the company, which are respectively handled by the Compliance Department and by an outside law firm. Furthermore, matters concerning executives can be consulted with and reported to Audit & Supervisory Board Members, who are independent from the management, through an external point of contact.

SoftBank Corp.'s hotline has been verified to be in conformance with the “Guidelines for Private Enterprises Regarding the Development and Operation of Internal Reporting Systems Based on the Whistleblower Protection Act” and therefore successfully obtained Consumer Affairs Agency's Whistleblowing Compliance Management System certification for two consecutive years since February 28, 2020.

Compliance structure

Efforts to
Promote Compliance

Training

The contents and method of delivery are varied depending on your job nature and seniority because we understand that the necessary volume and scope of information is not the same for everyone. Hence we prepare different programs for fresh graduates, newly hired, managers and senior executives considering their job nature and experience.

The topics we cover include but are not limited to temporary staffing, harassment and bribery, as we develop separate learning materials as new compliance risks are identified.

Compliance Awareness Month

Compliance Awareness Month is held annually for the purpose of enhancing the compliance awareness of all senior executives and employees. We offer online courses on selected compliance topics and a compulsory diagnostic test.

Corruption
prevention initiatives

“SoftBank Code of Conduct” states our determination in maintaining appropriate relationships with political and governmental officials and prohibits any behavior that can be interpreted as a corruptive practice. We commit in conducting fair business practices on the premise of complying with anti-bribery laws and regulations of each jurisdiction. SoftBank Corp. strictly bans any member from engaging in any form of corruptive practices as recommended by the Transparency International’s “Business Principles for Countering Bribery”.

SoftBank Corp. through “Rules Concerning the Maintenance of Proper Relationships with Civil Servants, etc.,” and “Internal Approval Request Regulation” ensures that our employees and officers are never involved in any corruptive practices whether direct or indirect. The above Rule and Regulation specify application and screening procedures regarding the provision of entertainment, gifts, and anything of value to civil servants, application and screening procedures regarding the appointment of agents, internal procedures involving political contributions, donations and sponsorship, the creation and storage of such records, and prohibition of facilitation payments. Moreover, we conduct regular checks over all entertainment fee incurring applications as part of our preventive measures.

Thus far, no cases of corrupt actions have been discovered.

All our business partners and suppliers are required to comply with “Supplier Ethics and Rules of Conduct” which prohibits them from engaging in any form of bribery.

Responsible political participation

SoftBank Corp. values responsible participation in politics and policymaking in order benefit both our stakeholders and other members of the society. Such determination is reflected in our Code of Conduct which includes a clause on how to maintain an appropriate relationship with governmental officials.

SoftBank Corp. remains politically neutral. The amount of political contributions to political parties or groups are strictly within the prescribed limit of the Public Offices Election Act, Political Funds Control Act and other relevant laws and regulations. Also, we do not fund individual politicians.

All political contributions are subject to the approval by the Board of Directors and shall be disclosed on our website accordingly. We, hereby, confirm that no political contribution was made in the FY2020.

For more details, please see the ESG Data Book.