Compliance

Compliance

1. Fundamental Approach

Compliance in today's society is not enough just to comply with laws and regulations, or to comply with internal regulations such as flight rules and maintenance rules, which are formulated based on government directives in accordance with laws and regulations. The essence of compliance is to guarantee that a company accurately understands the social obligations placed on it and behaves accordingly. In our opinion, this also includes abstaining from actions that are morally repugnant, even if they are not illegal.

2. Promotion Structure

Skymark has established a compliance system based on the "Compliance Regulations". The Risk Management Committee, consisting of executive directors, full-time corporate auditors and executive officers, monitors the compliance system, and provides instructions or advice to the Internal Control Promotion Office, which centrally manages compliance-related matters within the Company. Moreover, the Internal Control Promotion Office regularly reports to the Board of Directors on the status of compliance within the company. In addition, Compliance Officers have been appointed at each headquarters and each airport branch, and are working with the Internal Control Promotion Office to promote the strengthening of compliance systems within the respective divisions.

3. Implementation of Compliance Education

Compliance education is provided to all officers and employees to ensure that they have the correct knowledge of compliance and that they are capable of acting based on sound judgment. Each fiscal year, the Internal Control Promotion Office formulates a compliance education implementation plan, and conducts training for new employees, training at airport branches, training for executives, and training by lawyers commissioned by the Internal Control Promotion Office.

As an air carrier, Skymark is obligated to establish and make functional a safety management system. The safety management system is a mechanism for managing safety-related risks and refers to a series of safety-related risk management activities, such as collecting and sharing safety information, identifying hazards, analyzing the risks, implementing corrective actions as necessary, and evaluating the effectiveness of the corrective actions taken. To ensure proper implementation of this activity, we provide thorough compliance training from the perspective of safety management.

4. Anti-Harassment Initiatives

The “Harassment Prevention Regulations” were revised according to the revised Labor Measures Comprehensive Promotion Act (effective since June 1, 2020), which stipulates mandatory measures to prevent power harassment. In addition, we regularly conduct a "Harassment and Workplace Environment Survey" in an effort to understand the status of harassment and the workplace environment within the company, and the results of the survey are reflected in our compliance training in an effort to create a more pleasant working environment for employees.

5. Whistleblowing System

In accordance with the “Whistleblowing System Operation Regulations”, we have established an external and internal contact point for whistleblowing to ascertain compliance-related information and to resolve issues. This reporting window is open to all executives and employees, including part-time and temporary employees, as well as those who have been retired within the past year. In principle, confidentiality of information related to the content of the report is strictly enforced, and it is guaranteed that no person will be treated unfairly for making a report or for cooperating in an investigation of a reported case. In addition, the "Whistleblowing System Operation Regulations" have been revised in response to the revision of the Whistleblower Protection Act and the publication of the "Explanation of Guidelines Based on the Whistleblower Protection Act (Consumer Affairs Agency)," and it is expected that it will enable us to grasp internal risk information as quickly as possible and exercise self-cleansing.

In 2021, the number of whistle-blowing cases at Skymark were 1.14 per 100 employees, which are higher as compared with other companies (about double the average number of whistleblowing incidents reported by Security Protection Network Co.,Ltd. (External Reporting Service), suggesting that employees are highly aware of compliance and that the whistleblowing system is easy to use. We will continue to maintain a reliable and effective whistleblowing system to prevent the occurrence of situations that could lead to a decline in corporate value.

6. In the Event of Non-compliance

In the event that a violation of compliance is recognized, the Company takes strict action, including disciplinary action in accordance with the employment regulations.