As a core trading company in the ANA Group, ANA Trading Co., Ltd. is continually striving to improve corporate governance in order to maximize corporate value and satisfy all stakeholders.

The board of directors holds both regular and ad-hoc meetings as the highest decision-making body of the company, and makes decisions related to legal issues, the articles of association, and other important matters.

As of April 2011, the board of directors consists of 10 Vice Presidents, one of whom is an external director. The company has appointed three operating officers, who attend management meetings together with directors and auditors. These meetings are held twice a month, and make decisions on company policy and management issues.

The company has appointed three auditors, including one external auditor, all of whom attend the board of directors, as well as regular and ad-hoc board of auditors, to make decisions on the auditing policy and auditing work.

At the board of directors in May 2006, the policy for our operations was defined (eight policy items for the internal control system) based on the Companies Act. We have set up an internal control system in line with this policy, and regularly review and improve it. In July 2008 we set up a CSR Promotion Committee chaired by the president, with four expert subcommittees: Compliance Risk Management Committee, Food Safety Committee, International Security Trade Control Committee and Consumer Product Quality Control Committee, to strengthen internal controls.

As a consolidated subsidiary of ANA, we are also required to carry out and monitor internal controls related to financial reports based on the Financial Instruments and Exchange Act, and so we take various measures to prevent fraud and errors in financial reports. Our own internal audit division, the audit division of ANA and the auditing company also check these financial reports.

We regularly remind all executives and employees that they are required to comply with the ANA Group Compliance Regulations as well as our own compliance regulations, and to act ethically. The Compliance Risk Management Committee specifies important compliance policies, and members of this committee are appointed as CSR Promoters Managers by each division of each group company and ANA Trading Co., Ltd. to promote compliance in their respective businesses. The results are reported regularly to the CSR Promotion Committee, and also at the management Committee or board of directors as necessary. To help discover compliance problems promptly, we use the helpline of the ANA Group.

In order to strengthen compliance, we held totals of 23 compliance seminars with 479 participants in 2010, to provide training on subcontracting law, information security and food safety. In 2010, we focused on specific compliance issues. We also monitor executives and employees' awareness of compliance by an annual questionnaire survey within the ANA Group, and any problems revealed are quickly corrected.

We work closely with the ANA Group, which has set up a Compliance Risk Management Committee and a Safety Planning Dept, to handle daily problems and emergency situations. These sections were in charge of responding to the flu epidemic in 2010 and the Great East Japan Earthquake of March 2011.

To strengthen information security, we began using our Information Security Manual in June 2010, which defines the organizations responsible for information security, as well as the use, storage, and disposal of confidential information. Led by the CSR Promotion Office, we have revised the former rules on information control, and hold regular training meetings to ensure confidentiality, integrity and business continuity throughout the company.