HOYA Group Compliance Organization

The HOYA Group has established the Head Office Compliance Division under the HOYA Group Chief Compliance Officer (CCO), and appointed a Compliance Officer in each business division. In addition, the Head Office Compliance Division operates a hotline for receiving whistleblowing complaints (HOYA Help Line). However, the Audit Committee is directly in charge of whistleblowing complaints related to Executive Officers and the CCO, who constitute the upper organization of the Compliance Division, and the Audit Committee Office serves as the point of contact for receiving such complaints. The content of and responses to whistleblowing complaints made to the HOYA Help Line are reported by the CCO to the Audit Committee on a regular basis. Of note, any unfair treatment of whistleblowers and persons seeking advice (including any retaliatory measures such as dismissal, salary reduction, personnel transfer and harassment) is prohibited.

HOYA Help Line: Employee whistleblowing and consultation system

As part of its compliance system, the HOYA Group established the HOYA Help Line in 2003 as a service for receiving Group-internal and external whistleblowing reports and requests for advice. This is a framework to accept whistleblowing reports from inside and outside the Group, including the employees of business partners for early identification of problems when there have been violations of laws, regulations, or the HOYA Global Code of Conduct and smooth communication to top management while protecting whistleblowers. The aim is to ensure the soundness of the entire Group through quick and appropriate responses to such issues. In addition, information on whistleblowing complaints is also reported by the CCO to the Audit Committee on a quarterly basis.

We are creating an environment in which advice can be sought easily, including accepting whistleblowing complaints and consultation requests 24 hours a day on the Web in multiple languages, making consultation available in the local language, and allowing anonymity of whistleblowers. Having established rules on the operation of the HOYA Help Line in compliance with laws and regulations, we protect whistleblowers by prohibiting any acts that constitute the unfair treatment of whistleblowers and respond to escalations by giving consideration to the confidentiality of information to ensure whistleblowers’ anonymity.

In fiscal 2023, there were 280 whistleblowing complaints made to the Global HOYA Help Line, of which 67% were related to the workplace environment and 12% were related to HOYA’s system.

In addition, since fiscal 2023, cases of harassment received by Human Resources Division have also been shared with the Compliance Division to strengthen measures and training.

In fiscal 2023, there were no whistleblowing incidents inflicting a serious impact on HOYA’s businesses.

Number of Whistleblowing Incidents (Global)

* Ratio of whistleblowers to the total number of employees in the country where the whistleblowing and consultation system has been introduced

HOYA Code of Conduct

HOYA believes that if each and every employee acts fairly with high ethical standards in good faith, not to mention complying with laws and regulations, it will translate into “stakeholders’ trust.” Based on such a view, in 1997 we established the HOYA Code of Conduct, which clearly defines the standards of conduct for each and every employee. We have since repeatedly revised the Code while reflecting the enactment of new laws and regulations and the amendment and abolition of existing ones, as well as changes in society. Also, we check the behavioral guidelines in workplace activities and utilize the Code to raise employees’ awareness as our basic policy for compliance.

Having translated the Code into 27 languages in consideration of the circumstances of HOYA, which operates businesses on a global scale, we are making the Code thoroughly known within the Group by such means as making employees do a read through in the group to which they belong once a year and conducting online education and verification tests. In fiscal 2023, the participation rate in online education and verification tests targeted at all employees in the HOYA Group was 98%.

Prevention of Harassment

We have established the HOYA Group Policies and Guidelines for Measures to Prevent Harassment, which set forth measures and guidelines to prevent harassment, protect the dignity of employees as an individual and prevent workplace disorder and any obstacles to work. Based on the Guidelines as well as laws and regulations in each country, we conduct education and training on harassment prevention measures targeting all employees of the HOYA Group. For managers in Japan, we conduct training on manager-oriented harassment prevention measures.

Furthermore, we conduct initiatives to instill and ingrain compliance on an ongoing basis, such as posting information via the intranet and on bulletin boards, etc., and creating awareness-raising pamphlets and posters. From time to time, we post self-check tests (Q&A) on noncompliance incidents that are likely to occur in familiar situations as well as contents for understanding the essence of compliance through in-house case studies via the intranet and on bulletin boards, etc., so that employees can check compliance again when given the opportunity to do so and thereby gain a higher level of awareness.