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 have a high sense of ethics, follow all applicable laws and internal rules, and act in accordance with social common sense while also reporting and consulting with superiors or using the Compliance Hotline to resolve issues in the event that a violation or an act which is a potential violation is discovered.

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

    We respect human rights and do not tolerate discrimination or harassment on the basis of race, ethnicity, religion, nationality, birthplace, gender, gender identity and sexual orientation, age, disability, or illness.

  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 conduct business activities through fair competition in the marketplace regardless of anticompetitive actions and maintain relationships with business partners that are fair and enable mutual development.

  5. Proper use and management of company assets

    We use and manage company assets in accordance with the proper rules, and we do not use them to obtain individual or unlawful benefits. Moreover, we do not engage in transactions involving conflicts of interest without the company's permission or insider trading.

  6. Promotion of a Mutually Pleasant and Comfortable Working Environment

    We recognize and respect each other's diversity to promote innovation throughout the company while also respecting diverse styles of work and striving to improve occupational safety and health to maintain and promote a working environment that is easy for anyone to work in.

  7. Social Contribution and Environmental Conservation

    We value resources and strive to preserve the global environment while also contributing to society in a sustainable manner through the resolution of social issues and dialog 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 respect the privacy of our customers, business partners, and employees and protect and manage personal information, confidential information, and other information assets in the proper manner while also doing our best to protect such information from information security threats.

  10. Appropriate Relationship with Politics and Government

    We maintain appropriate relationships with political and governmental officials and do not contribute to corruption or corrupt actions such as giving or receiving inappropriate gifts or entertainment.

  11. Insulation from antisocial forces and criminal acts

    We have no involvement whatsoever with antisocial forces or criminal acts 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.

In the Compliance Department, compliance violations including bribery and corruption as well as acts which may be a potential violation are regularly reported to the CCO, and the CCO supervises the management conditions and policies concerning overall corrupt actions. In addition, regular reports concerning those conditions are also provided to the Board of Directors and the Audit & Supervisory Board.

Moreover, the “SoftBank Code of Conduct” is disseminated to all employees who work at the SoftBank Group, including SoftBank Corp. and its subsidiaries and affiliated companies, to encourage compliance with the law and corporate ethics in their daily work.

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 established the “Compliance Hotline” that all executives, employees, and suppliers of SoftBank Corp. and its subsidiaries can use to consult or report compliance violations or potentially violating acts when they become known. Consultations and reports shall be handled at the appropriate time and in the appropriate manner after performing a sufficient investigation, and persons consulting with and reporting to the hotline are guaranteed not to be subject to any form of retaliation regardless of the details.

To make the “Compliance Hotline” easy to use, information may be received in person by telephone, email, or postal mail, and anonymous consultations and reporting are also supported. 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 was 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 was registered under the Internal Reporting Systems certification (self-declaration of compliance) of the Consumer Affairs Agency on 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 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 strictly bans any member from engaging in corruptive practices as recommended by the Transparency International’s “Business Principles for Countering Bribery”.

In the “Rules Concerning the Maintenance of Proper Relationships with Civil Servants, etc.,” SoftBank clearly prohibits application and screening procedures regarding the provision of entertainment, gifts, and other forms of gain to civil servants, application and screening procedures regarding the appointment of agents, internal procedures involving political contributions and donations, the creation and storage of such records, and facilitation payments to maintain and operate a framework so that employees do not participate in acts of corruption. Moreover, application procedures are checked on a regular basis from the perspective of preventing corruption.

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 values responsible participation in politics and policymaking in order not to only benefit our stakeholders but also 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 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 FY2019.

For more details, please see the ESG Data Book.