Since our establishment, we have been conducting our business with the aim of creating a fair and highly transparent used car distribution market. In order to earn the trust of our customers, we have a strong desire to ensure that we have an operating system and rules in place to enable us to conduct our auto auctions smoothly and to guarantee that our daily operations are always conducted in the fair and equitable manner in which they need to be executed.
Moreover, since auto auctions are conducted by dealing with a lot of important information such as data on members and detailed information about auction lots and successful bids. If such information is not properly managed, it may become impossible to provide a "fair and impartial" forum for auto auctions to be conducted. Furthermore, it is also important for the functions of the used-car distribution process to be closely related to the administration in terms of issues like the registration procedures etc. and for various documents to be prepared without errors or deficiencies.
From this perspective, we constantly strive not just to improve our company's growth rate, but also to enhance the social status of the entire industry, by thoroughly complying with all the necessary regulatory and other requirements and by conducting our auto auction operations in a "fair and impartial” manner.
Basic Principles of Compliance
We have established and codified the basic principles of our compliance policy as the “USS Code of Conduct and Ethics”, and our directors take the lead in respecting and adhering to our corporate ethics. We have also created and published a “Compliance Manual” in order to thoroughly enforce the “USS Code of Conduct and Ethics”, and to ensure that each employee is thoroughly informed of its content through internal training programs, etc., and aim to achieve full compliance with laws and social rules and to firmly establish our corporate ethics.
Risk Management System
We think that our Risk Management System is closely related to our Internal Compliance System, and we have established our "USS Behavior and Code of Ethics" to improve awareness of corporate ethics and comply with laws and regulations. We have created and published a “Compliance Manual” and conducted in-house training, etc., in an effort to comply with laws and regulations, social rules, and to firmly establish our corporate ethics.
In addition, in order to promptly detect and correct behaviors and actions that violate or are contrary to it, we have established and are operating the USS Corporate Ethics Helpline, an internal reporting system for USS Group employees.
The Company’s Risk Management System consists of the Auction Management Headquarters for risks related to the auto auction business, the System Headquarters for risks related to information processing, and the General Headquarters for risks related to finance, personnel and disaster etc. We always strive to respond to risks and prevent their recurrence, and have a system in place that reports to the President through the Director in charge who also reports to the Board of Directors about risks that affect management.
Large Scale Earthquake Response - Business Continuity Plan (BCP)
USS has a manual that prescribes responses to a major natural disaster. This manual includes items concerning responses to a large-scale earthquake and measures to be prepared for an earthquake. In addition, there are training programs to give everyone at USS a thorough understanding of the BCP.
To confirm the safety of everyone at USS following a large-scale earthquake, USS has system linked to the earthquake bulletins of the Japan Meteorological Agency that automatically sends messages to all USS personnel. This system makes it possible to quickly determine the status of everyone in the event of an earthquake.
Data Management System for Disasters
In order to protect transactional data from disasters, we have contracted with inland data centers with a low risk of earthquakes and tsunamis, and we have also arranged for an adequate system of backup facilities to be in place.
The systems and data formats are standardized at each venue, and so, even if a disaster occurs in any specific location, the venues in the surrounding area will provide support and attempt to achieve a prompt recovery, and the handling of processes such as the settlement of moneys and fund transfers will be distributed to the surrounding area, we have established a system that will not become congested or delayed in such circumstances.
Moreover, in order to properly manage the information related to automobile auctions, the input terminals for our automobile auctions are operated independently from external networks. In addition, we have also improved the system, and have introduced a monitoring system that allows us to check who has accessed information, what type of data it was, and when it was viewed. We always keep logs of all access, of any kind, made to the information that is highly important to our business operations to ensure that this is such access is only available to authorized employees of the Company.
There were no incidents of violations of information security laws in the fiscal year that ended in March 2019.
In order to promptly redress and obviate any acts or actions that may result in our Company losing the trust of society at large, such as violations or infringements of laws and contracts, violations of the Company’s Articles of Incorporation and regulations, violations of the "USS Code of Behavioral Ethics", or abuse or misappropriation of rank or status, etc. As a countermeasure to such breaches, the Company has set up and operates the USS Corporate Ethics Helpline which is an internal reporting system for Group employees.
The scope of the "USS Corporate Ethics Helpline" extends to cover not just full-time employees but also temporary and temporary employees, etc., and accepts consultation and notification messages via email. The reception desk is set up at a third-party organization (within the premises of Integrex Inc.), with the USS Headquarters subsequently being informed and notified of the contents received. However, unless obligated by law, the names and affiliations involved will not be reported to the USS Headquarters without the express consent of the adviser and the whistleblower, thereby ensuring that the anonymity of the information provider and the neutrality of the system is maintained.
Corruption and bribery form one of the major risks that can seriously impair trust in a Company. In order to maintain a sound relationship with our members, traders and other stakeholders, we have clearly stated anti-corruption in the “USS Code of Conduct and Ethics” and ensure that all of the employees of the Group are thoroughly aware of it.
(Dealings with Suppliers)
The Executive officers and employees of the Company should not give or accept any excessive or unreasonable gifts or entertainment from members or dealers in any circumstances whatsoever.
Moreover, they should not make any offer of any illegal benefit or profit to any particular member in relation to the Company’s services.
(Related Party Transactions)
The Company, which shall be taken to mean the officers of the Company and their relatives within their second degree and any companies in which either a financial stake or a share is owned by these persons (in the case of listed companies, a company or companies with a holding equivalent to 1% or more of the shares in issue), shall be prohibited from entering into any transactions, other than transactions related to automobile auctions, conducted by any corporation in which a person that is substantially involved in the control or management enters into a transaction with the Company (excluding transactions conducted by the Company and the Company's subsidiaries). In cases involving automobile auction transactions, these transactions are to be referred to the Board of Directors in advance and should, provided that the circumstances surrounding the transaction are the same as apply for general members, obtain the approval of the Board, so as not to harm the common interests of the Company and its shareholders. The status of such transactions is to be reported to the first meeting of the Board of Directors held each year after the conclusion of the Ordinary General Meeting of Shareholders, and a deliberation is to be made as to whether or not these transactions are to be continued.
Initiatives to Eliminate Antisocial Elements
In our "USS Code of Conduct and Ethics", we clearly state our Company’s stance of severing and refraining from all relations and dealings with antisocial elements as follows, and we have made it thoroughly well-known to all employees of the Company Group that the Company will respond to any and all unreasonable demands with a firm and resolute attitude.
(Dealing with Anti-social Groups and Individuals)
No response is to be made to any requests for special transactions or money, etc., from antisocial individuals and organizations. Moreover, it is prohibited to take out subscriptions to, or to place advertisements in, any newsletters or magazines published or issued by sokaiya (corporate extortionists or racketeers that threaten to disrupt shareholder meetings) or similar individuals.
Furthermore, so as to thoroughly sever any relationships with anti-social elements even more forcefully than is usually achieved, the Company is building close relationships with specialist external agencies such as the police and lawyers with specific jurisdiction in this field, and has established an internal system so that the relevant departments can cooperate and coordinate their activities in gathering, managing, and maintaining information on anti-social elements.