Internal Control System

Internal Control System

Basic Policy for Developing an Internal Control System

On March 19, 2025, at Board of Directors, Asia Asia Educational Incorporative (hereinafter referred to as "this corporation") decided on the following basic policy for this corporation with regard to establishing a system to ensure that the performance of Director, Board of Directors' duties complies with laws and regulations and the Asia Asia Educational Incorporative University Contributions Act (hereinafter referred to as "University Contributions"), and to ensure the proper conduct of business.
The internal control system is as follows:
(1) In order to promote internal controls, an internal control promotion manager (hereinafter referred to as the "promotion manager") shall be appointed. The promotion manager shall be one of Executive Director, Board of Directors.
(2) The Promotion Manager will promote internal control by reviewing the establishment and operation of internal control and working to improve it.
 
1. Management system for business operations
(1) Board of Directors shall meet at regular intervals and on an ad-hoc basis as necessary to deliberate and decide on important matters concerning the execution of business operations, in accordance with laws and University Contributions and the Articles of Endowment, after hearing the opinions of Board of Trustees on necessary matters, and shall oversee the performance of duties by Director, Board of Directors.
(2) In accordance with the "University Contributions" and the "Asia Gakuen University Contributions Act Bylaws," the roles, authorities, and structure of Board of Directors and Board of Trustees shall be clarified, and Board of Directors and Board of Trustees shall be operated appropriately.
(3) Based on the "Department of Duties and Authority Regulations," the duties of each Director, Board of Directors who executes operations will be clarified to ensure proper and prompt business operations.
(4) Clarify the division of duties and decision-making authority to ensure the appropriateness of the performance of duties by Director, Board of Directors, faculty and staff, etc., and to enhance the agile, effective, and efficient execution of business operations.
(5) Minutes of important meetings such as Board of Directors and the Board Board of Trustees and other information related to the performance of duties by Director, Board of Directors will be properly prepared, preserved and managed in accordance with the "University Contributions" and the "Document Handling Regulations."
(6) An internal audit office that is independent from business execution organizations will be established to regularly audit the status of duties of each business division in order to ensure the appropriateness and efficiency of business operations.
 
2. Risk management system
(1) Regarding risk management, we will establish a system and the "Asia Educational Incorporative Risk Management Regulations" to clarify roles and authority, methods for risk assessment, methods for responding to risks, etc.
(2) Personal information will be protected and appropriately managed in accordance with the "Asia Gakuen Policy on Personal Information Protection," "Asia Educational Incorporative Regulations on the Protection of Personal Information," and "Regulations for the Handling of Personal Numbers and Specific Personal Information."
(3) Risks related to business activities shall be managed autonomously by the departments responsible for executing business operations in accordance with laws and regulations and the Corporation’s rules and regulations.
(4) The Risk Management Committee will supervise and manage risks, and the Internal Audit Office will conduct audits as appropriate to ensure that significant risks are being properly managed without any omissions and report the results of such audits to chair, Board of Directors.
(5) Any significant risks that may have a significant impact on the management of the Corporation shall be discussed by the Risk Management Committee and, if necessary, shall decide on necessary measures, etc. and report them to Board of Directors.
(6) In preparation for disasters, accidents, and other emergencies, we will establish regulations regarding response organizations and information and communication systems, etc., and will provide ongoing education and regular training.
(7) Regarding research activities, in order to ensure proper accounting of research funds through internal checks and balances, prevent research misconduct, and protect intellectual property, the University will establish rules and regulations and take necessary measures.
(8) The Risk Management Committee will identify and review risks related to business operations every year and report the results to Board of Directors. Board of Directors will manage the risk management system.
 
3. Compliance System
(1) In order to enhance the organizational culture in which Officer and faculty members comply with laws and regulations, the "University Contributions," and the Corporation's regulations and conduct business activities with a firm sense of ethics, Asia Educational Incorporative Promotion Regulations shall be established.
(2) In order to foster and establish a compliance awareness among all Officer, faculty and staff of the corporation, we will continue to provide education and awareness-raising activities to Officer and faculty regarding the prevention of misconduct, etc., and ensure that such activities are thoroughly disseminated.
(3) The Corporation will establish a permanent reporting system that allows anonymous consultations from both inside and outside the Corporation to prevent misconduct and promote a system for prompt investigation and correction. No one will be treated disadvantageously for consulting about compliance or reporting violations to the reporting system or Auditor.
(4) The Internal Audit Office shall audit the performance of duties by faculty and staff members from the perspective of compliance and report the results to chair, Board of Directors and Auditor. chair, Board of Directors shall take necessary improvements based on the results of the audit.
(5) If any violations of laws, regulations, or University Contributions acts are discovered, the Compliance Promotion Committee will promptly grasp the situation in accordance with the "Asia Educational Incorporative Compliance Promotion Regulations" and report it to Board of Directors without delay, while also working with external experts to respond appropriately.
 
4. Improvement of the audit environment (a system to ensure the appropriateness of audit work by Auditor)
(1) Auditor shall conduct Auditor in a fair and unbiased manner in accordance with the Auditor Regulations.
(2) Auditor shall audit the legality and appropriateness of the performance of duties by Director, Board of Directors and others through attending important meetings such as Board of Directors and Board of Trustees, as well as by inspecting, reviewing and questioning important documents.
(3) Auditor shall audit the appropriateness of the resolutions and decisions made by Board of Directors regarding the establishment of the internal control system.
(4) Auditor shall audit the information storage and management system and the information disclosure system, including the status of preparation, storage, management and disclosure of important documents and information.
(5) To assist Auditor in their duties, independent assistant staff shall be assigned at the request of Auditor.
(6) The assistant staff will perform duties to assist Auditor in their duties under the direction and orders of Auditor and will not receive directions or orders from anyone other than Auditor. Auditor’ opinions will be respected regarding the transfer, personnel evaluation, and disciplinary action against the assistant staff.
(7) The assistant staff will accompany Auditor to important meetings such as those of Board of Directors and Board of Trustees, as well as regular meetings with chair, Board of Directors.
(8) If Director, Board of Directors or faculty and staff members discover any facts that may cause significant damage to the Corporation or any acts that violate laws, regulations, the "University Contributions" or other regulations, they will immediately report them to chair, Board of Directors, Executive Director, Board of Directors and Auditor.
(9) Director, Board of Directors, faculty and staff members, etc. shall not be subjected to detrimental treatment on the grounds that they have made a report to Auditor without any improper intent.
(10) When requested by Auditor to report on the status of performance of duties, etc., Director, Board of Directors and faculty and staff members shall respond promptly.
(11) chair, Board of Directors shall meet regularly with Auditor to exchange opinions and deepen mutual understanding toward the implementation of the business and the sound development of activities.
(12) When Auditor makes a request to the Corporation for advance payment or reimbursement of expenses in connection with the performance of his/her duties, or for payment to creditors of debts, the Corporation shall comply with such request promptly, unless the Corporation can prove that the expenses or debts in question are not necessary for Auditor to perform his/her duties.
 
5. Revision and abolition of this policy
If the need arises to revise this policy, it will be amended by a resolution of Board of Directors.

Structure of the internal control system at Asia Educational Incorporative