Compliance Actions
At a meeting of Elpida's Board of Directors, the Board passed a resolution concerning a basic policy
"Resolution to Establish a System to Ensure the Appropriateness of Company Business Activities (Establishment of an Internal Control System)"
As part of the system that is based on this basic policy, a Risk Management and Compliance Committee has been created to serve as an institutional vehicle for studying and deciding on comprehensive policies related to compliance and risk management which are vital to the continuation and expansion of business of Elpida.
In regard to compliance, the Risk Management and Compliance Committee has thus far considered, decided and implemented the following representative policies:
- Establishment and Education of an Elpida Code of Conduct
Elpida has established an "Elpida Code of Conduct" [1] which serves as a guideline of standards for all company employees and Directors.
The "Elpida Code of Conduct" includes legal compliance matters. In addition to the conduct of company business, the Code touches on various rules that should be observed in relation to "society," "customers and business partners," "competing companies," "shareholders and investors," "employees and other individuals" and "company and company assets."
part of an effort to educate employees with respect to the contents of the "Elpida Code of Conduct", the Code has been distributed to all employees with a message from the chair (Elpida's CEO) of the Risk Management and Compliance Committee urging all employees to comply with the Code's contents. Continual education to ensure employees' understanding and compliance with the Code is provided.
Elpida Code of Conduct - Internal Reporting "Compliance Helpline" System
Elpida has also established a system to allow business departments or individuals within the company to report any violations of laws or the Elpida Code of Conduct. This system, which features an internal Compliance Helpline, will attempt to undertake early detection and correction of any alleged legal violations or other infractions. Ultimately, Elpida's goal is to have in place an acceptable set of management practices that will be in good faith compliance with applicable laws and regulations.