Compliance

Last updated: 2025-11-20

1. Positioning and Governance

ASIACOM GLOBAL TRADING Japan Desk is operated and managed by ASIACOMMUNICATION Co., Ltd., a Japanese company headquartered in Tokyo. The Japan headquarters defines and oversees the compliance framework for the entire ASIACOM Group, including regional offices in Hong Kong, Taiwan, and the Philippines.

While trade execution is conducted on the ground in each region, governance, information management, and the overall compliance policy are centralised in Tokyo. This structure enables us to combine local expertise with a consistent standard of integrity and control.

2. Basic Policy and Principles

The Group’s compliance policy is based on the principles of integrity, transparency, and responsibility. We commit to complying with applicable laws and regulations, respecting international norms, and following internal rules established by the Japan headquarters.

  • Act fairly and honestly in all business activities.
  • Respect the rights and dignity of all stakeholders, including clients, partners, and employees.
  • Maintain accountability through clear decision-making processes and documentation.

3. Legal and Regulatory Compliance

For the Japan Desk, our primary legal basis is the law of Japan, including the Companies Act and the Act on the Protection of Personal Information (APPI), while also complying with the laws, regulations, and guidelines of each jurisdiction where group entities operate.

  • Compliance with corporate, tax, labour, and other general laws in each relevant jurisdiction.
  • Adherence to international trade-related rules, such as customs regulations, import/export controls, and sanctions regimes.
  • Implementation of appropriate KYC (Know Your Customer) and AML/CFT measures in collaboration with regional offices.

4. Business Conduct and Anti-Corruption

We prohibit bribery, corruption, and fraudulent practices in any form, and promote a culture of fair and ethical conduct throughout the Group.

  • Prohibition of improper payments, kickbacks, or benefits to public officials or private counterparties.
  • Rules on gifts, hospitality, and entertainment to avoid conflicts of interest or the appearance of undue influence.
  • Expectation that employees and officers act in the best interests of the Group and avoid personal conflicts of interest.
  • Respect for human rights; discrimination and harassment are not tolerated.

5. Data Protection and Information Management

Personal data and confidential information handled via the Japan Desk are managed primarily under Japanese law, including APPI, and in accordance with our separate Privacy Policy. We also take into account data-protection requirements in the countries and regions where we operate.

  • Protection of client, partner, and employee information against unauthorised access, leakage, or misuse.
  • Implementation of appropriate technical and organisational security measures for our systems and infrastructure.
  • Responsible use of AI and digital tools, ensuring that data is used only within legitimate and clearly defined purposes.
  • Careful handling of cross-border data transfers, subject to contractual safeguards and applicable legal requirements.

6. Trade Compliance and Sanctions

As an organisation engaged in international trade, trade compliance is a core element of our Group compliance framework.

  • Compliance with export control regulations and restrictions on strategic or dual-use goods.
  • Screening of counterparties and transactions against applicable sanction lists and restrictions.
  • Appropriate documentation and record-keeping related to trade flows, contracts, and customs declarations.
  • Cooperation with financial institutions and logistics partners to ensure compliant transaction structures.

7. Whistleblowing and Speak-Up

To detect compliance issues at an early stage, the Group maintains internal channels through which employees and other relevant parties can report concerns in good faith.

  • Reported matters are handled with appropriate confidentiality and care.
  • No retaliation is tolerated against individuals who raise concerns in an honest manner.
  • Where appropriate, findings are escalated to management at the Japan headquarters and corrective actions are implemented.

8. Training and Awareness

Compliance is not just a set of rules but a culture that must be maintained and strengthened on an ongoing basis. The Japan headquarters promotes training and awareness activities across the Group.

  • Provision of training on legal and regulatory updates relevant to our business.
  • Education on anti-corruption, data protection, and trade compliance topics.
  • Sharing of case studies and lessons learned within the Group to prevent recurrence of issues.

9. Continuous Improvement and the Use of AI

Our compliance framework is reviewed and enhanced over time, taking into account changes in law, market conditions, technology, and feedback from stakeholders.

  • Use of AI and analytics to identify anomalies, trends, and potential compliance risks more efficiently.
  • Periodic review of internal rules and procedures to ensure they remain practical and effective for lean teams.
  • Alignment of Group compliance with the governance and risk management frameworks supervised by the Japan headquarters.

By combining a Tokyo-based governance and compliance framework with the practical experience of our regional offices, ASIACOM aims to remain a trusted partner for clients and counterparties in Hong Kong, Taiwan, the Philippines, and beyond.