Corporate Governance

Ensuring Business Ethics, Compliance and Anti-corruption

All Sun* Group employees shall keep in mind when conducting themselves that "ethical, conscience-based judgments" are the basis of our business. We shall aim to build a fair workplace, develop sound business relationships, and through our work, contribute to the development of society. Based on this general policy, we have established 10 basic principles that form the basis of our daily activities and that have been designated as the principles of the Group's Code of Ethics.


General Principles

  • 1. We shall conduct sound business operations, with full awareness of our social responsibility and public mission in relation to our business.
  • 2. We shall comply with laws and regulations including the underlying spirit of legislation.
  • 3. We shall conduct business fairly and transparently, based on the principle of self-responsibility.
  • 4. We shall place priority on the safety and satisfaction of our clients, and diligently provide products and services at a fair price.
  • 5. We shall respect human rights and the individual rights of all related persons, and contribute toward sound socio-economic development.
  • 6. Being in an era of globalization, we shall respect cultural traditions and customs.
  • 7. Should we have to choose between profit and ethics, we shall not hesitate to choose ethics.
  • 8. We shall stand firmly against anti-social forces.
  • 9. We shall strive to leave a richer and fairer society to our future generation.
  • 10. Should we face difficulties regarding ethical issues, we shall strive to find solutions that satisfy everybody.

Compliance System

Sun* Group has established a Compliance Committee chaired by the Representative Director and the heads of each department as committee members. In principle, the committee meets each quarter to promote the legal compliance of Sun*'s activities. In addition, if there is an actual or potential compliance violation, a Compliance Committee meeting will be promptly convened to implement measures to prevent a recurrence. We also conduct educational programs and tests targeted at all employees of Sun* as well as contractors twice a year to raise their understanding and awareness of corporate ethics and compliance.


In engaging in global operations, Sun* Group will ensure a full understanding of the anti-corruption policies required of companies under local laws and regulations as well as international norms. We will implement necessary anti-corruption measures with the help of inside and outside lawyers to prevent risks of corruption, such as provision of entertainment and gifts, or rendering of money and other benefits to pursue illicit benefits. In addition, we provide training courses to officers and employees engaged in overseas business to teach and share with them a common understanding that certain business practices in developing countries involving entertainment, gifts and provision of benefits constitute corruption risks unique to overseas business.

Political Donations

Sun* Group does not make donations to political parties, political funding groups, or individual politicians. The total amount of political contributions in 2020 was zero.

"Number of employees disciplined/dismissed due to violation of anti-corruption policy: None (FY2020) Fines, penalties and settlement costs related to corruption: None (FY2020)"

Tax Compliance

1. Tax Governance

Sun* Group regards tax risk as one of its major risks. The Compliance Committee evaluates the tax risks of each group company, including transfer pricing, on an annual basis, and the evaluation results are reported to the Board of Directors.
Tax issues in each country and region are addressed not only by receiving support from external experts, such as tax accountants, but also through direct communication with the tax authorities as necessary. We maintain a sincere attitude to the tax authorities and strive to maintain and improve tax-related corporate governance.

2. Transfer Pricing Taxation

Regarding transfer pricing taxation risk, Sun* Group complies with tax laws of each country and region, as well as the OECD (Organization for Economic Co-operation and Development) guidelines. We document and manage the cost of transfers to each country and region, information of which is shared with our business departments in addition to our internal tax department, to ensure that transactions are made at arm's length.

3. Tax Planning and Tax Avoidance

We strive to effectively use preferential taxation systems of each country and region where possible in our normal business activities to ensure a suitable tax burden. We do not transfer value created to low tax jurisdictions and do not use tax structures intended for tax avoidance outside the spirit of the law.

Sun* determines countries and regions in which to establish foreign subsidiaries to carry out ordinary business activities and does not establish subsidiaries in "tax havens" for the purpose of avoiding taxes. Sun* will properly file and pay taxes should anti-tax haven rules apply.

Corporate Governance

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