１．Basic Principles
Aizawa Asset Management Co., Ltd. (hereinafter referred to as “the Company”) respects the human rights of its officers and employees ( including officers, each such person an “Employee”) and all those who have relationships with the Company, including business partners, customers, and investees ( each such person, a Related Party”). , In order to protect the dignity of all Employees and Related Parties, we do not tolerate any form of harassment. We will take the necessary countermeasures to ensure that all Employees are respected as individuals and can work without being harassed. In order to prevent power harassment, sexual harassment, harassment related to pregnancy, childbirth, childcare leave, nursing care leave, etc., and all other forms of harassment, we have established a “Anti-harassment Policy” and “Anti-harassment Regulations” as basic policies that Employees must follow. We take a strict approach to any form of harassment.
２．Definition of harassment behavior
Harassment in the workplace or in business relationships includes sexual harassment, power harassment, and harassment related to pregnancy, childbirth, childcare leave, and nursing care leave, as described below. This definition also applies to inappropriate behaviors outside the workplace if these misconducts occur in the course of work. Speech and behavior directed at or received from not only Employees but also people outside the company, such as Related Parties, will be covered by this definition.
(1) Sexual Harassment Sexual harassment refers to the act of causing disadvantage to other Employees or Related Parties, or harming the working environment, through unwanted sexual behavior (comments or actions). This includes not only behaviors between members of the opposite sex, but also between members of the same sex. Regardless of the sexual orientation or gender identity of the employee or related party, any sexual action or behavior can be considered sexual harassment.
(2) Power Harassment Power harassment is defined as speeches or actions from a position of superiority that go beyond what is necessary and reasonable in the course of work, and that cause disadvantage to other Employees or Related Parties, or that harm the working environment. As used in this Anti-harassment Policy,
- the phrase “harm the working environment” refers to causing physical or mental pain, discomfort, fear or aversion in the workplace or in human relationships, etc., and causing a degree of interference that cannot be overlooked in terms of work; and.
- the term “power harassment” applies not only to speeches and actions by superiors towards subordinates, but also to the relationships between seniors and juniors, colleagues, and those with superior relationships in external transactions.
(4) Others Any behavior that causes discomfort or disadvantage to the other party, or that worsens the work environment or infringes on an individual’s personality or dignity, through speeches or actions related to race, nationality, beliefs, occupation, background, family, etc., is considered as harassment. It could even be a violation of human rights and illegal.
３．Establishment of a harassment consultation desk and consultation procedures
・Aizawa Asset Management Co. Ltd. General Affairs Department
7th Floor, Tokyo Shiodome Building, 1-9-1 Higashi-Shimbashi, Minato-ku,
Tokyo Japan 105-7307
＊Call: +81-3-6263-9690
＊FAX: +81-3-6263-9679
・Aizawa Securities Group Co., Ltd. Audit Committee
7th Floor, Tokyo Shiodome Building, 1-9-1 Higashi-Shimbashi, Minato-ku,
Tokyo Japan 105-7307
＊Call: +81-120-311-941
＊FAX: +81-120-311-941
※Consultation methods: 1) letter, 2) phone call, 3) fax, to the contact information listed above
・Shinsei Sogo Law Office (Esq. Yasuhiko Nishimoto)
VORT Kioizaka 5F, 4-3-29 Kojimachi, Chiyoda-ku
Tokyo Japan 102-0083
＊Call: +81- 3-3222-0701
＊FAX: +81- 3-3222-0702
＊This number is forwarded to the answering machine automatically. Please follow the voice instructions.
※Consultation methods: 1) letter, 2) phone call, 3) fax, to the contact information listed above
４．Investigation and countermeasures
Upon receiving a request for counseling regarding harassment, we will start an investigation on the matter as quickly as possible so as to confirm the incident accurately and make all efforts to take appropriate action. All Employees and Related Parties have the right to have counseling regarding harassment, as well as the obligation to cooperate with our investigation of harassment incidents.
５．Strict adherence to privacy and confidentiality
We will take the utmost care to protect the privacy of the parties involved and will maintain confidentiality. It is prohibited to disclose any personal information, such as the names and contact details of the parties involved, the content of consultations, and the results of investigations, to third parties.
６．Prohibition of unfavorable treatment
There is absolutely no disadvantage to having counselling with our Consultation Desk. Also, no disadvantageous treatment will be given to Employees who cooperate with the investigation on the incident.
７．Prohibition of acts of retaliation and second harassment
The perpetrator of harassment is prohibited from taking any retaliatory action or any action that could be construed as retaliation against the person who consulted us, or against any other person involved who cooperated with confirming the incident.
８．Disciplinary action
Subject to the Employment Regulations, we will take disciplinary action against any of our Employees who committed harassment.
９．External countermeasures
In case we receive a request for consultation or inquiry from a Related Party regarding harassment done by our Employee, we will follow the procedure described in 4 to 8 above to respond to it appropriately. If our Employee is harassed by a Related Party, we will respond to the incident through the internal consultation service, protect his or her mental and physical health, and request such Related Party to take action so that the working environment will not be harmed.
１０．Internal Awareness
In order to prevent harassment, we strive to raise awareness on harassment issues inside the company through compliance training and training programs structured by the position level.