Principles and guidelines

Declaration of thorough compliance

AISIN endeavors to ensure compliance best practices under the Aisin Group Principles of Corporate Behavior. In addition, the Guideline in Compliance with Social Responsibility uses a question-and-answer format to provide employees with concise information on specific laws and regulations to pay heed to during the execution of work duties.

Organizational structure

Establishment of a Business Ethics Committee

The 12 main companies have set up a Business Ethics Committee or equivalent committee at each company as a structure whose function is to discuss important matters related to corporate ethics, compliance and to decide on policy in this regard.

Each committee, chaired by a member of top management such as the vice president, has met one to three times each year to deliberate since 1992.

Promoting widespread recognition of the whistle-blowing system

The 12 main Group companies have established a compliance hotline with internal contact points in each Group company, such as legal affairs departments and at external law offices to receive inquiries and notices on matters pertaining to compliance to promptly identify and correct inappropriate conduct.

Consultation is available to employees and their families as well as business partners^*. Regulations clearly stipulate that the name of the person filing a complaint or consultation as well as the content be kept confidential, and the Group adheres strictly to this rule. Also, manager training programs are conducted to ensure that no retribution, such as dismissal from work or pay reduction, will be incurred by an employee as a result of filing a complaint.

In FY2011, a focused effort was made to notify more employees of the compliance hotline and encourage its use through the use of internal newsletters and posters.

^* People who may use the compliance hotline differ slightly by Group company.

Compliance hotline contacts (12 main Group companies)

	FY2009	FY2008	FY2011
Internal contacts	234	209	195
External contacts	20	24	24
Total	254	233	219

Education and Training

Ensuring full awareness on the part of Employees

Among its rank-specific and theme-focused training programs, AISIN conducts compliance training as a means to raise awareness of relevant laws and regulations among employees.

In FY2011, training focused on the fundamentals of the Antimonopoly Law as well as the management of export duties and contracts.

In addition, October of each year has been designated as Business Ethics Campaign Month. During this month, a call for new banner ideas and group discussions at workplaces fosters opportunities for each and every employee to reflect on their normal routines and consider business ethics.

To spread awareness of compliance, workplaces conduct case studies. Using challenging examples of compliance issues posted on the Group intranet, members of workplaces discuss what the problem is and how to prevent it. Case study examples are also made available in Portuguese.

Number of compliance training program participants
(12 main Group companies)

		FY2009	FY2010	FY2011
By rank	Officers	145	215	157
	Managers	842	2,035	672
	General employees (Number of new hires and mid-career hires)	2,509 (1,299)	2,855 (996)	2,026 (666)
	Agency workers	172	74	184
Total of rank-specific training		3,668	5,179	3,039
Total of theme-focused training		1,958	4,521	5,284

Poster to enhance ethical business activities

Compliance awareness survey

In FY2011, a compliance awareness survey targeting employees was conducted throughout the entire Group, to which 35,243 employees responded. The results of the survey indicated that all Group companies share a similar understanding of the compliance hotline system and awareness towards workplace harassment.

From FY2012, AISIN will further implement Group-wide measures to create a bottom-up structure across the Group.

Fundamental policy and organizational structure

Formulating guidelines, and establishing a system to prevent information leakage

Aisin Seiki has established the following guidelines, among other measures, to prevent the leakage of confidential and personal information. These guidelines require that confidential and personal information of employees, customers and business partners be handled in full compliance with relevant laws and societal norms.

Under a Company-wide system, Aisin Seiki places confidentiality managers in each department to take measures to prevent information leakage. To respond to any information leaks or suspected leaks that should occur, the Company has established an Emergency Countermeasures Headquarters to investigate each leak, prevent secondary damage and provide for the parties affected.

Cyber information security

Thorough management to prevent information leakage

Aisin Seiki specifies procedures for protecting its information and information systems in its Cyber Information Security Management Rules. The Company designates security levels for each building according to the importance of the information housed, and manages the facilities and monitors who enters and exits based on the respective security levels.

To prevent information leakage, the Group has established a strict registration system for company-owned computers and external storage media such as USB devices, and requires that employees receive permission when taking these items from the premises. All computers are secured using wire locks. In addition, data in important digital documents are protected using security software such that they cannot be viewed by external parties.