Compliance Structure Overview

We establish The Air Water Group Code of Ethical Conduct, which provides all officers and employees of Air Water and its group companies with guidelines to help them act in strict conformance with the laws and regulations and behave in an ethical manner. In addition, we have a Compliance Handbook, which breaks down the code and provides examples of violations in an easy-to-understand manner. The handbook is distributed to all group employees with the aim of raising their awareness of the vital importance of ethical conduct and compliance.
In the organizational structure for compliance management, the Compliance Center has been set up as the supervising department under the direct control of the representative director, and is in charge of integrated management of compliance-related problems. The chief of the Compliance Center is appointed from among executive officers. Starting from January 2018, each company has a department responsible for compliance associated with organizational reform to expedite decision-making for ensuring thorough compliance. The responsible department of each company seeks to closely cooperate with the Compliance Center, thereby enhancing the compliance structure of the group companies.

Compliance Committee

Air Water has established the Compliance Committee as a consultative body in which relevant divisions get together and discuss compliance issues. The Committee considers specific measures concerning the policies and instructions on compliance given by the representative director, and other issues, and also discusses ways to deal with compliance violations if they occur.

Internal Reporting System

Air Water has established an internal reporting system in order to ensure compliance-based management. Anyone who becomes aware of violations of laws or internal rules, or any acts which may violate them, can make a report. Points of contact for reporting have been established both inside and outside the company, and there is a provision ensuring that a person who makes a report will not suffer any disadvantage.
The points of contact, or hotline, for this internal reporting system are communicated to all group employees by such means as the “compliance poster” displayed at all business sites.

Risk Management Structure Overview

The Compliance Center, which is under the direct control of the representative director, manages, as the supervisory division for the entire group, the risks recognized as particularly important for business activities of the Air Water Group; namely, the risks concerning compliance, safety, disaster prevention, environmental preservation, and quality assurance.
Individual risks concerning information security, intellectual property, expansion of overseas businesses, business contracts, etc., are managed through actions at the level of each responsible division such as by formulating internal regulations, preparing manuals, and providing education and training, as well as through prior inspection and authorization procedures.
With the Compliance Center serving as the secretariat, the risk management examination meeting is held regularly, helping to bolster the risk management framework of the entire group.

Crisis Management Framework

Initiatives for Information Security

Air Water is fully aware that protecting the information of customers, etc., is an important social responsibility of any company. This means not only complying with laws and regulations related to specific personal information or personal information protection but also requiring all officers, employees, and other related parties engaged in corporate activities to ensure information security and protection of information in accordance with internal information security management regulations.

Major Information Security Measures

Dissemination of rules
  • Conducting training against targeted email attacks
Management of information devices
  • Encryption of information devices
  • Periodic inventory counting using asset management tools
Illegal use prevention
  • Password control and periodic changing of password
  • Controlling entry into/departure from data center
  • Banning connection of personal PC to company network, banning connection of personal media to company PC
Measures against external threats
  • Complete separation of external network and intranet using firewall
  • Introduction of latest antivirus software
  • Web filtering and blocking unsolicited emails
  • Monitoring unauthorized communication with outside parties