The Cyber Audit Office accepts and handles reports on wrongful requests or facts related to corruption practices exploiting the position of officers and employees. Reports should be made using the informant’s or reporter’s real name, but they are handled in strict confidence. When an anonymous report is made, the case may not be investigated, or the outcome of the investigation may not be notified.

Types of reports

1Illegitimate requests for or information concerning the provision of money, valuables, or entertainment;

2Misuse or abuse of job-related authority or illegitimate solicitation or requests;

3Illegal transactions; and

4Other acts violating the Ambassador Group Ethics Code

Protection of informants or reporters

1Confidentiality ensured: Acts of disclosing or alluding to the identity of the informants or reporters without their consent are strictly prohibited.

2Protection of status: The informants or reporters are protected from any unfavorable disposition or discrimination in transactions or by their organization because of their reporting, statement, or provision of related information.

3Abatement of responsibility: The relevant informants or reporters may receive abated disciplinary punishment for their negligence or error as discovered in connection with the report.

• 01.

  Responsibility and Duty to (external) Guests

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  The bedrock of Ambassador's business is in the Guest-first mindset. By providing services from the guest's point of view, we establish trust with the guests and ensure their satisfaction

  1-1. Respecting the Guests

  • Remember that the guests are the foundation for the company's growth; always be open to their suggestions.
  • Think and act from the point of view of guests and strive to ensure their satisfaction by being ready to serve them anytime.
  • Staff should refrain from using facilities for guests so as not to interfere with their comfort. (Except when addressing them.)

  1-2. Offering values to the Guests

  • Constantly create values that can satisfy and substantially help the guests based on the mindset that the guest's development is our development.
  • Provide guests with the best-quality service at reasonable prices and respond promptly to the guest's reasonable demands.

  1-3. Keeping Promises to the Guests

  • Speak only the truth and always keep promises to the guests.

  1-4. Relationship with the Guests

  • There should never be a personal relationship with the guest outside of work.
  • Never receive any entertainment or benefits from the guests, and do not oblige them to give tips.

  1-5. Protecting the Interest of the Guests

  • Actively inform the guests of the notices that they have the right to know.
  • The guest's property is to be regarded as if it were the company's and should not be used without their owner's consent.
  • When acquiring information related to the guests, do not use it for other purposes than those they consented to.
  • Put guests' safety as first priority when conducting management or business activities.
  • Do not participate in unethical activities that might harm the guests' interest.
  • Refrain from getting involved in arguments with the guests due to their unfair demands, but immediately report to the manager for further instructions.
• 02.

  Shares Responsibilities and Duties toward Customers (internal)

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  Ambassador Hotel Group officers and employees will perform their mission through incessant self-development and fair performance of their duties by establishing an upright sense of value as Ambassador with a credo of honesty and sincerity.

  2-1 Basic Ethics

  • The officers and employees respect each other's personality and keep proper decorum and manners.
  • The officers and employees exert their best performing their duties with the owner's mind maintaining pride and self-esteem.
  • The officers and employees always maintain an honest and sincere attitude to maintain the dignity and honor as Ambassador members.
  • The officers and employees abstain from smoking in places other than those designated spots.
  • The officers and employees will not use or acquire the company's assets for personal purposes without authorization by strictly distinguishing the public and private affairs.

  2-2 Performance of Missions

  • The officers and employees should share the company's vision and values and perform their mission faithfully based on the company's policies.
  • The officers and employees should perform their duties doing their best using legitimate methods, and should also observe all social customs and statutes, the company's policies and systems.
  • The officers and employees should clearly understand their authority and responsibility, and make decisions within their authority to serve the goals pursued by the company, maintaining sense of accountability for their behavior.
  • The officers and employees should enhance the effectiveness and efficiency of their service with an active cooperation and smooth communication with peers and other departments.

  2-3 Self-development

  • The officers and employees should make efforts steadily to meet the image of Ambassador talents through incessant self-development while establishing the image of employees desirable to the company.

  2-4 Fair Performance of Duties

  • The officers and employees should perform all of their duties fairly and rationally and exert to create a sound corporate culture.
  • The officers and employees should not accept financial benefits of any type that may compromise the fairness of their duties from any stakeholders.
  • The officers and employees should not commit any unethical or illegal acts that may be denunciated by the society in daily life or in connection with duties.
  • No superiors should issue any job instructions that violate statutes or company regulations. Subordinate employees given any such instruction may reject such instructions and shouldn’t be suffered from any disadvantages even if he/she notifies the details to the company (next higher superior, HR department etc.).
  • The officers and employees should not cause any losses to the company or damage its reputation in daily life or in connection with duties.

  2-5 Prohibition of Provision of Gifts to Other Officers or Employees

  • The officers and employees are prohibited from providing gifts to other other officers or employees.
  • However, this does not apply to gifts a superior offers to his/her subordinates for organizational morale, inexpensive birthday gifts provided with the cost equally shared among the team members (exchange of gifts with other team members is prohibited), or exchange of gifts commemorating anniversary.

  2-6 Prohibition of Monetary Transactions between Officers or Employees

  • Monetary transactions between officers or employees are prohibited as they may weaken organizational discipline or result in excessive losses, including bankruptcy of the individuals.
  • The officers and employees are prohibited from borrowing or lending money from or to other officers or employees or from providing loan guarantee or joint guarantee for a loan.

  2-7 Prevention of Sexual Harassment in Workplace

  • The company will thoroughly strengthen its efforts to prevent sexual harassment as it may cause damages to the company as well as the individual victims.
  • The officers and employees should abstain from making obscene or vulgar remarks or demanding others to offer drinks or dance.
  • The officers and employees should not view indecent Internet sites.
  • The officers and employees should not make any sexual assessment or analogy of bodily features of workplace colleagues.
  • The officers and employees should abstain from making any unnecessary bodily contacts and should not utter words that emphasize a stereotype sex role.

  2-8 Prohibition of Use of Illegal Software

  • The officers and employees should not use unlawful software.

  2-9 Thorough Safety or Risk Management

  • All officers and employees should are liable or responsible for maintaining safety of the company.
  • The officers and employees should abide by statutes related to safety and thoroughly comply with safety rules in all conditions.

  2-10 Mutual Respect between Officers or Employees

  • The officers and employees should abstain from impolite or slanderous remarks concerning peers while maintaining basic etiquettes required in workplace.
  • The company does not tolerate any discrimination or disadvantage inside the company based on factors that are irrelevant to capabilities of individuals or company's benefits, including school, region, blood kinship and gender.
  • The officers and employees should not commit any acts distressing superiors, peers or subordinates (including words, non-lingual acts or visual acts).
  • However, this does not apply to constructive criticism or supervisory actions or statements related to job performance.

  2-11 Prohibition of Leaking Customer or Internal Information

  • Personal information concerning customs should never be disclosed to any third party without their advance consent.
  • The officers and employees should prevent information falling under secret of partner companies from disclosed to anyone that is not authorized in or outside the company.
  • The officers and employees should never divulge any internal information, including company secrets or information concerning new business projects, to any third party without advance approval by their superiors.
  • The officers and employees should prevent important documents or records (business, sales other similar information) from being leaked to competitors or specific parties by nominating those who are responsible for their safeguarding.
  • The officers and employees should not disclose any trivial information related to the company's financial status, strategy or plan, HR or organizational information, or important information related to its reputation or competitiveness when requested by an outside party. Before providing any such information, it should be asked to the PR department when requested by a person serving for the press, or to the relevant department when requested by others.

  2-12 Fair Treatment

  • Equal opportunities should be granted based on the ability and aptitude of the officers or employees.
  • The company appraises and compensates its officers and employees justly by applying fair criteria based on their capabilities and performances.
  • The company provides its officers and employees with equal opportunities to improve their ability and does not discriminate them based on education, gender, religion, birth place, age, bodily handicap, marriage, nationality, or race.

  2-13 Promotion of Creativity and Development of Talents

  • The company creates maximum possible conditions for promoting creative thinking and autonomous actions by its officers or employees.
  • The company establishes systems and creates atmosphere so that its officers or employees may freely make proposals or recommendations or express their difficulties.
  • The company actively supports its officers or employees in developing their ability and develops talents on a long-term perspective.
  • The superiors should not spare advice or guidance to their subordinates considering their aptitude and potential.

  2-14 Declaration of Outside Lecture

  • The officers and employees should obtain advance approval from HR department for giving a lecture outside the company based on the service regulations. This applies to any lectures outside the company irrespective whether any compensation (lecture fees) is received or not.
• 03.

  Responsibilities and Duties toward Shareholders

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  The company protects the shareholders' return on their investment by realizing stable profits through efficient and sound business or managerial activities.

  3-1 Protection of Shareholders' Interests

  • The company exerts to maximize its earnings to provide financial rewards to its shareholders.
  • The company respects their legitimate right to know, just requests, proposals and formal decisions.
  • The company maintains transparent managerial systems to build up mutually trusted relations with the shareholders.
  • The company maintains an accurate accounting system based on generally accepted accounting standards.
  • The company preserve, protects or increase the shareholders' assets, faithfully protecting their income.
  • The company exerts to ensure an appropriate assessment of the shareholder or enterprise value through active Investor Relations (IR) activities.
• 04.

  Responsibilities and Duties toward Partners

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  All transactions with partner companies should be conducted based on the principle of autonomous competition while opportunities are guaranteed for their equal participation. Long-term win-win coexistence and development should be sought by deploying mutual trust through fair and transparent transactions.

  4-1 Equal Opportunities

  • The company provides all qualified partner companies with opportunities to participate in registration or selection of partner companies for transactions.
  • The registration or selection of partner companies should be performed in a reasonable fashion based on objective and fair review criteria.

  4-2 Fair Transactions

  • The partner companies should be selected in a fair and transparent manner based on the quality, price and reliability of products or services provided by them.
  • All transactions should be conducted fairly in mutually equal positions with sufficient advance consultation on conditions and procedures.
  • The relevant partner company should be consulted to sign the document in advance when transaction conditions or terms are modified. (Preparation of transaction agreement) The company should exert to secure fairness through thorough application of standard scores during periodic assessment, which should be established clearly.
  • The company should not commit any unfair acts of any type using its advantageous position. It should not make any unfair request to or accept improper reward from business accounts.
  • The company should secure objectivity and appropriateness by notifying the relevant partner company in writing without failure when it discontinues transactions with a regular partner company.

  4-3 Prohibition of Entertainment

  • The officers or employees should not accept any unlawful money or entertainment placing priority on the company's reputation and interests in dealing with partner companies.
  • The officers or employees should encourage the partner companies to adhere to the purposes and spirits of Ambassador Ethics Code by explaining about them.
  • The officers or employees should share expenses for all gatherings (for golf, tennis etc.), except for official corporate events.
  • The officers or employees should not exchange gifts or valuable items for any justification or occasion of holidays, anniversaries, business travel, irrespective of the amount size.
  • The officers or employees should always pay their own share when they have tea or meals with partner personnel (including overseas business trips).
  • The company may apply disadvantage to a partner company in business transactions if its officers or employees provide any of the Ambassador officers or employees with gifts, entertainment, financial benefits.
  • Entertainment or gifts should be provided within the extent of usual practices adhering to the relevant statutes if any such need be offered.
    * Interpretation of the extent of ‘usual practices' Beverages, simple snacks, communication or transportation convenience which are provided in a limited quantity in inevitable cases for performing job duties fall under the extent of usual practices.

  4-4 Pursuit of win-win development

  • The company should support various managerial activities of partner companies in diverse means and should not attribute any of its difficulties to them.
  • The company should actively support partner companies to grow with a long-term competitiveness and should share profits generated through innovation.
  • The company should make efforts together with partner companies to maintain fair transactional order while generating a clean transparent transactional atmosphere.
  • The company should periodically improve the conditions of service contractor personnel by listening to their managers.
• 05.

  Responsibilities and Duties toward Society (community)

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  Ambassador Hotel Group follows the relevant statutes, respect business customs, and pursue competitive advantage through fair and transparent means in all regions where it operates business activities. Further, it contributes to the development of communities by growing into a sound business through reasonable business development.

  5-1 Observance of Statutes

  • Ambassador Hotel Group observes all statutes and respect business customs in all local and foreign regions where it operates business activities.
  • All its personnel assigned to overseas posts should acquaint with and comply with law provisions or customs in the relevant region.

  5-2 Observance of Market Order for Free Competition

  • Ambassador Hotel Group respects the market competition order in all places based on the principle of free competition.
  • Ambassador Hotel Group practices well-intentioned competition without infringing benefits of or exploiting of weakness of the competitors unfairly.

  5-3 Utilization of Information Obtained Legitimately

  • Ambassador Hotel Group utilizes information obtained legitimately based on statutes and business customs.
  • Ambassador Hotel Group does not disclose information unfairly concerning competitors even if obtained legitimately.
  • Ambassador Hotel Group does not slander or make ungrounded comparison with competitors through advertisement or other similar means.

  5-4 Development of Reasonable Business

  • Ambassador Hotel Group conducts its business respecting the social values in both domestic and overseas regions.
  • Ambassador Hotel Group endeavors to grow its business based on the stable growth of the community.
  • Ambassador Hotel Group abstains from speculation in real properties or other similar acts hurting the national economy or generating alienating mind among the general public.
  • Ambassador Hotel Group rejects corruption that hurts sound business activities.

  5-5 Contribution to Development of Community

  • Ambassador Hotel Group contributes to the development of the nation by creating jobs and paying taxes faithfully and discharges all its duties and responsibilities as business citizen through steady performance of its corporate social responsibility.
  • Ambassador Hotel Group contributes to the development of the community by guaranteeing the participation of its officers and employees in sound community activities.
  • Ambassador Hotel Group humbly accommodates just demands of local residents and all social classes and exerts its best to resolve such demands.

  5-6 Prohibition of Participation in Politics

  • The company does not involve itself in politics and does not permit any political activities in workplace.
  • The company does not provide any illegal contributions to or share expenses of any electoral candidates, political parties or committees directly or indirectly.

  5-7 Protection of Environment

  • The company exerts its best to protect the nature and preserve clean environment.
  • The company discharges its social responsibility for protecting environment through thoroughly environmentally friendly business activities.
  • The company exerts its best to eliminate waste through conservation of and education on resources.
• 06.

  Addenda

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  Article 1 [Enforcement Date]

  • • This ethics code will be enforced from 1 November 2018.

  Article 2 [Code of Conduct for Ethical Business]

  • In order to let the officers and employees to practice this ethics code thoroughly, the company develops and implements Ambassador Code of Conduct for Ethical Business that should be followed by the officers and employees to become "The First Choice" which is our motto selecting them out of the ethics code provisions.

  Article 3 [Citation and Disciplinary Action]

  • The company awards prizes or citations to officers or employees who have contributed to the ethical business of the company while abiding with its ethics code. The company takes disciplinary actions against officers or employees who have violated the ethics code or code of conduct for ethical business.

  Article 4 [Consultation or Advice]

  • The officers and employees should consult or obtain advice from audit office of Ambassador Hotel Group in interpreting or following the ethics code or code of conduct for ethical business.

  Article 5 [Interpretation Norms]

  • The interpretation or decision by Audit Office of Ambassador Hotel Group will prevail if the ethics code or code of conduct for ethical business fails to provide clear definitions in connection with ethical business activities or if any dispute arises in connection with the interpretation.

  Article 6 [Relations with Other Company Policies]

  • The ethics code prevails over the other company policies or regulations as the code constitutes the backbone to practice ethical business.

01.Purpose

02.Terminology

• Gift “Gift" refers to products, favors, certificates, coupons, memberships, admission tickets, etc., that are given without compensation.
• Entertainment “Entertainment" refers to providing convenience such as reception, including food/golf or transportation/lodgings.
• Convenience “Convenience" refers to assistance other than monetary goods or entertainment reception, including transportation, lodging, touring, ceremonial assistance, etc.
• Staff “Staff" refers to all the employees who receive wages in return for providing service to their company.
• Reporter “Reporter" refers to all the staff who have the responsibility to report any incident of bribery or other illegal activities.
• Persons of Interest “Persons of interest" refer to all people, corporations, or other groups outside the company who/that are affected by the activities or decision making of the staff.