Basic approach

Directors, executive officers, and employees of the DeNA Group shall be required to be cognizant of its corporate social responsibility and to engage in their daily duties in accordance with the Group Code of Conduct and the requirements of “DeNA Promise” and “DeNA Quality,” in full compliance with applicable laws and regulations and in a manner consistent with social norms and ethical standards. The heads of the various organizational units, such as executive officers, unit heads, and general managers, shall operate their respective units to ensure that each member conducts their affairs in a manner consistent with the foregoing.

DeNA Group Code of Conduct

The DeNA Group has established the Group Code of Conduct to promote a deep understanding of social responsibility and ethical conduct. The Group Code of Conduct requires that all officers and employees be cognizant of laws and regulations in their daily business activities and engage in their daily duties in full compliance with applicable laws and regulations and in a manner consistent with social norms and ethical standards.
This Group Code of Conduct addresses important risk factors, including abiding by applicable laws and regulations regarding antitrust and competition; abiding by laws and regulations related to prohibition of bribing public officials in Japan and internationally, including each country’s criminal laws and the U.S.’s Foreign Corrupt Practices Act (FCPA); abiding by applicable labor laws and regulations, including minimum wage; prohibiting forced labor and child labor; respecting human rights; appreciating regional and cultural differences and diversity; prohibiting all harassment, including sexual harassment; prohibiting discrimination on the basis of race, religion, gender, age, nationality, place of origin, disability and other factors; abiding by equal opportunity in hiring; ensuring fair disclosure; and preserving the environment.
Also, as stipulated in the Group Code of Conduct, the DeNA Group respects international standards, including the UN’s International Bill of Human Rights (including the Universal Declaration of Human Rights), Guiding Principles on Business and Human Rights, and the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.
The DeNA Group will always act in accordance with a high standard of ethics in all its corporate activities, and faithfully observes and implements the matters set forth in the Group Code of Conduct.

Establishment and Maintenance of Compliance Structure

Establishment of Compliance and Risk Management Unit

The Compliance and Risk Management Unit is responsible for the compliance and risk management of the DeNA Group. The Compliance and Risk Management Unit shall be responsible for (a) creating guidelines and manuals and (b) establishing and operating the Group’s compliance program, including education initiatives (such as compliance training), for the purpose of disseminating information to employees about laws, regulations, and internal rules, etc., to ensure that the conduct of individual employees and the organization comply with applicable laws and regulations and conform to social norms and ethical standards. The head of the Compliance and Risk Management Unit shall provide periodic updates to the representative directors and Board of Directors regarding the status of the Unit’s activities.

Legal Compliance Initiatives

In an effort to enhance the legal compliance structure, the DeNA Group endeavors to build a more effective organization by building a system of checks and balances through the selection of multiple outside directors independent of the DeNA Group, and complying with various laws and regulations in Japan as well as other countries and regions.
In addition, the Compliance and Risk Management Unit, which is a dedicated department that functions across all business departments, formulates the approach and provides appropriate suggestions for compliance and risk management while looking across the company as a whole, and coordinates with relevant departments, gathers information, and conducts awareness activities.
The Compliance and Risk Management Unit, together with the legal department, identifies compliance-related issues and formulates and updates various regulations, guidelines, manuals, and other rules preferable for addressing these issues in the DeNA Group.
The DeNA Group established Antitrust Guidelines with the aim to ensure thorough compliance with the Antitrust Laws, established Conflict of Interest Management Guidelines with the aim to avoid conflicts of interest for employees, and established Partner Guidelines with the aim to promote responsible corporate activities together with partners.
In FY2022 the DeNA Group established the DeNA Group Tax Policy with the aim to maintain and enhance tax compliance, and established the DeNA Group Human Rights Policy with the aim to promote initiatives to respect human rights.
Determining the protection, management, and legal handling, etc. of personal information and other information assets is highly necessary for the DeNA Group business operations, and thus these operations are conducted in the information security department in coordination with the Compliance and Risk Management Unit, based on the basic approach established by a dedicated committee of which the president & CEO is the head.

    • Bribery & corruption prevention initiatives The DeNA Code of Conduct expresses our belief that we can earn society's trust by not only complying with laws and regulations, but also by acting in accordance with a high level of ethics in all aspects of our corporate activities.
      With regard to bribery & corruption, DeNA believes it is important to conduct our business activities in a fair and ethical manner in accordance with the laws and regulations concerning bribery & corruption of the countries in which we operate, as well as our internal rules.
      DeNA has established the DeNA Group policy, code, and guidelines for the prevention of bribery & corruption to clearly state our stance to never offer or accept bribes and to not pursue benefits that can only be obtained through bribery or corruption.
      DeNA will develop rules regarding entertainment, gifts, invitations, donations, political funds, etc., as well as further enhance training and auditing to prevent bribery & corruption.
  • Handling conflicts of interest The DeNA Group established the Conflict of Interest Management Guidelines with the aim of providing more detail than was provided in the DeNA Group Code of Conduct on the prohibitions on conflicts of interest and how to avoid them, for conflicts of interest that can occur in the everyday work of individual employees.
    To avoid inappropriate influence from employee personal interests on company decision-making, the Guidelines define and elaborate on the aim and range of conflict of interest management, specific actions that may qualify as a conflict of interest, and procedures and mechanisms (management departments, how to consult on the matter, internal education, etc.), etc.
    With the Guidelines, the DeNA Group manages conflicts of interest for employees by deepening their understanding of conflict of interest management, taking action to avoid or eliminate conflicts of interest on a daily basis, and taking the necessary measures when a conflict of interest arises or is likely to arise.
  • Establishment of DeNA Group Tax Policy The DeNA Group recognizes that one of our corporate social responsibilities is to properly file tax returns and pay taxes in accordance with the tax-related laws, accounting-related regulations of each country and region in which we operate, and internal rules.
    In order to implement tax compliance initiatives at a higher level, the DeNA Group has formulated the "DeNA Group Tax Policy," which clarifies the basic approach to taxation that each and every officer and employee should comply with and what we should aim for, and passed a resolution on this policy at the September 2022 Board of Directors meeting.
    In compliance with the principles of this policy, the DeNA Group will conduct tax treatment with high transparency, ensure the appropriateness of taxation, minimize tax risks, and strive for sustainable development of society and enhancement of corporate value.

Compliance Violation Response

If the Compliance and Risk Management Unit or the internal audit department becomes aware (through the internal audit, internal reporting or otherwise) of any material violation of laws, regulations or the Articles of Incorporation, any inappropriate action or any possibility of serious risk of loss for the DeNA Group, it shall promptly report to DeNA’s directors (other than directors who may have a conflict of interest) and corporate auditors. DeNA has also established a Disciplinary Committee for the purpose of maintaining internal discipline and ensuring fairness in disciplinary actions for violations. In the event of problematic behavior, the committee meets as necessary and imposes disciplinary punishments in accordance with the employment regulations.

Compliance Training & Enhancing Awareness

At the DeNA Group we conduct compliance training in an online lecture format or in-person format for newly entering new grads and mid-career hires. We also conduct monthly compliance training in an e-learning format every month in Japanese and English for all officers and employees (including regular employees, contract employees, dispatch employees, part-time, and casual employees, etc.). Topics covered include the code of conduct and important topics based on the code of conduct such as compliance with various laws and regulations, harassment prevention, personal information protection, and insider trading prevention, etc.
The Compliance and Risk Management Unit reviews the content of training programs jointly with the legal department each fiscal year in response to changes in social conditions and the environment, as well as the status of the DeNA Group. The Compliance and Risk Management Unit also monitors and analyzes participation rates and training results to ensure that training content is disseminated to all officers and employees. In FY2022 training programs were held 12 times, and the number of participants was 2,312 (as of March 31, 2023).
In addition, through responses to questionnaires on the status of the organization, which are conducted twice a year, the DeNA Group checks the status of the penetration of compliance awareness and strives to enhance the system. Each organization works with the Compliance and Risk Management Unit to implement measures to raise compliance awareness.

Distribution of the Compliance Handbook

The Compliance and Risk Management Unit and the legal department jointly created a compliance handbook for all employees that includes content such as explanations of the Group Code of Conduct using specific examples and introductions to the risk management system and the whistleblowing hotline system. This handbook functions to disseminate knowledge to all employees on behalf of the representative directors.


Whistleblowing Hotline System

The whistleblowing hotline system is available to DeNA Group directors, executive officers and employees, as well as former employees and partner company employees, etc. Reports may be made anonymously. The whistleblowing hotline system also has the option to contact not just internal personnel but also the corporate auditors and external legal counsel. Under the Group Code of Conduct and internal regulations the anonymity and the confidentiality of whistleblowers is affirmed and disadvantageous treatment of whistleblowers is prohibited. In addition, in the case there is a report made to any of these points of contact, the internal audit department, which operates the whistleblowing hotline system, investigates as necessary. The internal audit department reports the summary of reports to the directors, corporate auditors, Board of Directors, and the head of the compliance and risk management department.
There is also a harassment hotline in the human resources department for any consultations regarding harassment.
In FY2022 there were 28 cases of consultation or reports, related to internal rules and regulations, and human relations, etc. via the whistleblowing hotline system and the harassment hotline.

● Process for reporting / consultation

Whistleblowing Hotline System
Whistleblowing Hotline System

*Page in Japanese, accepts English reports.