Legal and corporate compliance

Basic Approach to Corporate Ethics and Compliance

Guided by the Basic Policy on Corporate Governance, Hamamatsu Photonics has set forth the Basic Approach to Corporate Ethics and Compliance. This statement is posted on the Company’s internal website so that all employees can familiarize themselves with it.


Basic Approach to Corporate Ethics and Compliance was drafted by the president and CEO of Hamamatsu Photonics. The Company is in the business of light, and much about the nature of light remains unanswered. To pursue unknown and unexplored realms, each and every Hamamatsu Photonics group's employee must harbor a burning desire to know the truth. And because a company is the sum of the actions of its people, we expect of every employee a commitment to compliance and respect for human rights, as well as a determination to observe both the letter and the spirit of the law and international rules.


By organizing itself as a corps of employees with a strong sense of ethics, Hamamatsu Photonics aims not only to secure stable management but also to grow and prosper as an enterprise that earns the trust of stakeholders.


Basic Approach to Corporate Ethics and Compliance

Fundamental CSR policy and corporate code of conduct

Hamamatsu Photonics has established its Fundamental CSR Policy, which it discloses to the public. The Company also sets forth its Corporate Code of Conduct, with which every employee is expected to be familiar.


Fundamental CSR Policy


Corporate Code of Conduct

Compliance enhancement framework

The Company, led by  the Legal and Compliance Department, works tirelessly to ensure that all employees are familiar with its compliance framework. In addition, the Internal Audit Division confirms and strives to improve the awareness of employees while holding interviews with department leaders to confirm the status of enhancement and implementation of the compliance framework. Based on the results of compliance audits, the Internal Audit Division encourages departments and sections that have not taken up educational opportunities about compliance, whether within the Company or from external providers, to pursue in-house training. The Legal and Compliance Department has created a framework for constantly providing compliance education.


【Officer in charge of compliance】
Koichi Nagumo(Executive Officer, Deputy Chief of Global Management and Planning General Headquarters)

Instilling a compliance mindset

To enhance employees’ awareness of compliance issues, Hamamatsu Photonics regularly posts information on the Company’s approach to corporate ethics (compliance) on its internal website, as a call to attention for employees.


In addition, we continue to implement the following compliance mindset activities.

・Freshly hired employees and career-track employees in their third year of employment are provided compliance education.

・Suitable compliance training is also provided in tandem with audits by the Internal Audit Department.

・An awareness survey implemented for all employees every year to encourage their understanding of various regulations and compliance. The company investigate the state of unfair business practices through this survey.

・Distribution of compliance email magazine to all employees.

Whistleblower program

It is the responsibility of each and every employee to move compliance activities forward. If a misstep is spotted, the Company’s basic approach is to resolve the matter within the chain of management. Such resolution may not always be possible, however, and in preparation for such cases the Company has established a whistleblower program. The contact points for the whistleblower program are the Audit & Supervisory Board, the General Affairs Department, and the Legal and Compliance Department.


From the moment someone comes forward with an allegation, the Company takes prudent steps to maintain the secrecy of all personal and other information about the whistleblower, to protect the whistleblower from suffering any kind of disadvantage and abuse of rights due to his or her act of whistleblowing. When a whistleblowing event occurs, the contact point for the whistleblower, which is either the Audit & Supervisory Board, the General Affairs Department, and the Legal and Compliance Department, confers with officer, who is responsible for whistleblower matters. The opinions of attorneys and other outside specialists may also be solicited as necessary. These parties work together to investigate the matter in a fair and impartial manner. If the allegation of an illegal act is found to be true, disciplinary action is taken in accordance with the Employment Regulations.

The number of reports received through Whistleblower program is disclosed in the Governance section of ESG data.
ESG data


【Example of report content】
Illegal provision of benefits, bribery, fraud, unfair transactions, involvement with anti-social forces, criminal acts, harassment, human rights violations, content that violates laws and public interests, etc.

Preventing corruption

One of the Company’s key commitments to stakeholders is the prevention of bribery and other corruption. This pledge is at the very heart of our business, as we signaled to the world in August 2017 when we signed the United Nations Global Compact (UNGC). To advance its efforts to prevent corruption, Hamamatsu Photonics has completed preparation of in-house regulations to prevent corruption at overseas subsidiaries.

In May 2022, the Company held training for officers to inform and confirm the importance of anti-corruption (anti-bribery of foreign civil servants).

In FY2023, no violations of or sanctions against Hamamatsu Photonics or its subsidiaries occurred with respect to bribery.

Anti-competitive practices

Prohibiting the restriction of free competition is a core principle of the Company’s business. As part of our commitment to stakeholders, we direct all employees to make fair dealing and fair competition integral to our business activities.

In FY2023, no legal actions were taken against Hamamatsu Photonics in connection with any anti-competitive action, antitrust case or monopolistic behavior.

Prohibition of insider trading

The Corporate Code of Conduct of Hamamatsu Photonics clearly prohibits insider trading. The Company establishes regulations on management of inside information and ensures that all employees are familiar with them.

To provide all investors with a clear understanding of its business activities, Hamamatsu Photonics conducts a vigorous program of investor relations (IR). As it does so, the Company takes prudent steps to prevent unfair disclosure. Hamamatsu Photonics suspends IR activities during the silent period between the quarterly closing of accounts and the announcement of quarterly results. We also caution related parties against disclosure of insider information and take care to practice fair disclosure at all times in conducting IR activities.

Elimination of ties with antisocial forces

Hamamatsu Photonics understands that society expects and demands that it must eliminate all relationships with organized crime and other antisocial forces. The Company’s Corporate code of conduct clearly mandates the refusal of all relationships with any such persons or groups, and this information is circulated to all employees.

The Company also maintains close working relationships with local police and related organizations and strives to stay informed about antisocial forces.

Prevention of unlawful exports

Overseas sales account for approximately 70% of the net sales of Hamamatsu Photonics. Among those products are items capable of being applied or transferred to conventional and mass destructive weapons. Under the circumstances, the Company pays scrupulous attention to export control. Specifically, we stipulate internal compliance program on export control and have established an exclusive unit, the Export Control Group of Product Management Department, with overall responsibility for internal export control. In addition, the Company actively conducts not only export control judgment but also relevant information collection, internal training (more than 50 trainings a year for each department and each hierarchical level), annual audit and actions in partnership with public agencies to craft a robust framework for compliance and appropriate handling of export control.

Transparency regarding taxation

Hamamatsu Photonics has established its Fundamental CSR Policy and complies with all related laws, regulations and international rules, both in letter and in spirit. All employees are expected to conduct operations based on a strong sense of ethics. With respect to taxation, the Company strictly abides by the laws, regulations and rules of each country and region, in the spirit of the Fundamental CSR Policy, to pay due taxes in accordance with the content of its business activities.


【Officer in charge of finance, accounting and tax】

Kazuhiko Mori (Director, Senior Executive Officer and Chief of Finance and Accounting General Headquarters)