Compliance

“Compliance” at Touchstone means that all employees respect the laws and regulations in their day to day work, and that they do so with a strong sense of ethics. To be more precise, Touchstone has implemented certain measures such as the establishment of an ethics code and internal rules for the purpose of enhancing employees' respect for the law, implementation of compliance training for employees and the creation of a Compliance Hotline. In addition, improvements have been made to strengthen the company's compliance systems, for example with the establishment of a Compliance Committee and the appointment of Compliance Officers.

The internal standards, rules and manuals designed to ensure a clear understanding of laws and regulations are made available via Touchstone's intranet, providing a compliance education framework for all employees. Training programs are conducted in accordance with the roles of each employee.

Employees who have become aware of actions that may violate laws and regulations are able to report their concerns directly to Management through a Compliance Hotline. This hotline also allows such reports to go directly to an outside legal supervisor (an independent attorney), in addition to the designated executive officer. Information may be given anonymously, and employees have been informed that measures are in place to ensure that individuals who give their name when reporting violations do not suffer any negative consequences from their actions.

The Compliance Committee, consisting of several directors and officers including the CEO and the Chief Compliance Officer (Chief Internal Administration Supervisors), is in charge of establishing the internal controls system and regularly discussing important matters involving internal controls, in order to enhance the compliance system.

Compliance Officers (Internal Administration Supervisors) are appointed in each department to create a substantially stronger system for internal supervision activities at Touchstone. They are charged with ensuring that compliance is a strong part of the corporate culture, that business operations adhere to all laws and regulations and that activities conform to social standards from the standpoint of corporate ethics.