Basic View

The Infocom Group contributes to innovations in society through advancements in ICT. To embody this management philosophy, we promise to engage in compliance-based management. At the same time, we are committed to ethics first, which is the first tenet of our Group Employee Action Guideline.
Under these policies, the Group Corporate Code of Conduct provides a basic policy on which decisions and actions are based in connection with daily business operations. The Group Corporate Standards of Conduct define specific points for reference when putting these ideas into practice. Together, these two documents form the basis of the Infocom Group corporate ethics structure.

Compliance Education and Training

We have designated October as our Corporate Ethics Month, sponsoring CSRO lectures, conducting business unit training, and offering other programs to enhance awareness of ethics across our group. We engage in our work subscribing to high ethical standards, continuing to build our understanding of CSR, compliance, harassment, etc.

In addition, we aim to instill the knowledge necessary for operations through regular e-learning seminars and other training methods.

Internal Reporting System

We strive to strengthen Infocom Group compliance through the early detection and correction of wrongful acts. To this end, we established a system for the proper handling of consultations and reports from executives and employees of the Infocom Group concerning organizational or individual violations of laws and regulations.

Harassment Prevention

We describe our human rights activity policies within our Group Guidelines and Group Action Regulations, striving to comply strictly with these statements. We provide regular case study and other training to employees to encourage a better understanding of harassment and to prevent harassment from occurring within our organization. Infocom Corporation has established both internal and external help lines (compliance and harassment help line) for reporting and consultation.

Fair Trade and Anti-Corruption

The Infocom Group recognizes corruption and bribery as a serious risk factor that could undermine confidence in the company. Accordingly, we have clarified our basic anti-corruption policy. At the same time, we conduct employee training and other education to prevent bribery.

Anti-Corruption Policy

The Infocom Group does not tolerate bribery or other any other form of corruption. We comply with national, regional, and international laws and regulations concerning fair trade where we do business, and we conduct business with respect to international norms.

The Infocom Group Corporate Code of Ethics, Detailed Regulations on the Prevention of Bribery of Public Officials, Etc., and the Group Corporate Code of Conduct stipulate the following matters.

Group Corporate Code of Ethics


Article 2 (Basic Principles of Compliance)

  1. We expect all executives and employees of the Infocom Group companies to comply with laws and regulations as a matter of course, as well as act with integrity based on the ethics and values required of corporate and individual members of society. Sincerity of action is indispensable for increasing shareholder value.
  2. Based on this recognition, each company of the Infocom Group shall strictly observe social norms, ethics, and laws, and shall strive to engage in fair and appropriate business, conducting themselves in harmony with civil society. Each company of the Infocom Group shall also maintain and consistently implement its own corporate philosophy, code of conduct, and other regulations.
  3. Infocom Group companies shall require executives and employees of their own companies to understand the above basic principles fully and to act with integrity, thereby contributing to the dynamic growth of the Infocom Group.
Article 5 (Basic Policy)
  1. Infocom Group companies shall ensure that their executives, officers, and employees understand corporate ethics fully, and shall take fair and impartial action in the event of any violation of the Group Corporate Code of Ethics.
  2. Infocom Group companies shall not reward the performance of their executives, officers, or employees who violate corporate ethics.
  3. Infocom Group company executives and managers shall lead by example in corporate ethics.
  4. Infocom Group companies shall provide corporate ethics education and enlightenment proactively to their respective executives and employees to ensure all understand corporate ethics fully.

Article 14 (Disposition)
Any executive or employee committing a violation shall be subject to disciplinary action in accordance with the Employment Regulations and other internal regulations.

Enacted January 1, 2023

Detailed Regulations on Prevention of Bribery of Public Officials, Etc.

Group Corporate Code of Conduct


16. Maintain appropriate relationships with vendors and affiliates
We do not give or receive gifts or entertainment that deviate from social common sense. We never pay bribes to public officials.

(1) Gifts and entertainment

  1. When the other party is a public official (an officer or employee of a government agency or equivalent public organization)
    We do not provide entertainment, gifts, or other benefits to officers or employees of public offices or equivalent public organizations in violation of laws, regulations, or ethics.
  2. When the other party is a sales or purchasing business partner (private sector)
    If gifts or entertainment are required in the course of business operations, we shall do so within the bounds of social common sense. We do not engage in extravagant conduct or conduct that is biased toward any particular party.
  3. We do not provide or accept entertainment or gifts within the Infocom Group or among partner companies, except on occasions deemed necessary by the company.

(2) Donations

  1. If asked to make a donation to socialize with local communities or industry associations, or make a donation for disaster relief, we respond appropriately in accordance with the relevant regulations of the group company in question and the Infocom Group. We make donations only after careful consideration of the purpose, necessity, and effect of the donation in question.
  2. In principle, we do not make political donations. However, we will make the expenditures necessary for conducting business in accordance with the Infocom Group rules regarding responsibility and authority. Further, any such expenditures shall be within the scope of relevant regulations.

Enacted October 1, 2020

Anti-Corruption Education and Awareness

As part of our compliance education and training activities, we are conduct education and awareness-raising activities to prevent corruption, including bribery. As part of these activities, we distribute a Corporate Ethics Handbook that summarizes our Group Corporate Code of Conduct. We also issue notices and reminders via our corporate intranet to ensure corruption prevention is understood and practiced widely across our organization. 

Disciplinary Actions, Dismissal, Fines, or Penalties for Employees Resulting From Violations of Our Anti-Corruption Policy

The following data summarizes results regarding anti-corruption in the Infocom Group.


Disciplinary actions or dismissals of employees


Fines related to corruption

0 Yen

Assessment of penalties related to corruption


Defend against antisocial forces

The Infocom Group shall not engage in any relationship with antisocial forces that obstruct social order and sound business activities. Further, the Group shall strive to defend itself against such antisocial forces by working closely with the police and other outside professional organizations, as well as through a firm company-wide stance against such antisocial forces.

  • We reject any and all relationships with organized crime groups in our business activities, and we shall not have any relationship with said groups. We participate in and cooperate with measures implemented by the police and local governments to eliminate organized crime groups. We also endeavor to provide the police and local governments with information that contributes to the elimination of organized crime groups.
  • Our basic stance is that we never pay, make use of, or fear anti-social forces, including organized crime groups.
  • We reject any unreasonable demands, etc., from antisocial forces, responding to such demands in an organized manner. We maintain contact with the police and receive appropriate guidance.

Prohibit insider trading

The Infocom Group complies with laws and regulations related to financial instruments trading and the rules and regulations of securities exchanges. We educate employees on insider trading regulations and manage such inside information in accordance with the Insider Information Management Rules to maintain the social credibility of the company in the securities markets.
No cases of insider trading occurred in fiscal 2022.