NEWS

28 January 2022

How creative commerce can protect brands from becoming commodities in the e-Commerce marketplaces

With online shopping becoming the new normal, brands are pressured into joining the e-Commerce bandwagon. In this insightful read, Krishna Kumar, our Group Director for Strategy, Media and E-Commerce, deep dives into the crowded space of online marketplaces and offers tips for brands looking to make their move online.

 

E-Commerce marketplaces are a level playing field. Where legacy brands can compete with direct-to-consumer (DTC) brands, and large enterprises might tussle with SMEs. The landscape is quickly evolving and as marketplaces become more competitive, many brands seem to be compromising their long-term objectives with short-term targets. The outcome of this approach results in hefty discounting, with a focus on volume transaction over value as competing on price becomes the norm. To add on this, the increasing cost of doing business on these marketplaces is increasing their customer acquisition cost (CAC). 

The e-commerce basket is getting bigger and so is the cost of the basket

A Euromonitor report indicates that the value of ASEAN’s E-Commerce has grown almost six times in just four years - from USD9.5 billion in 2016 to USD54.2 billion in 2020. In the ASEAN region, e-commerce sales as a percentage of total retail sales hit 9%, up from 4% in 2018. Although the figure is in single digits, it is growing steadily. A Forrester report indicated that in the next five years, online retail sales in Asia-Pacific will double, growing from USD1.3 trillion in 2018 to USD2.5 trillion in 2023, with a compound annual growth rate (CAGR) of 14.0% and accounting for 28% of total retail sales!

Reaping the profits will not be easy. Profit margins can quickly dwindle if brands stay focused only on basket optimisation. When calculating the CAC besides cost of goods sold (COGS), marketing, marketplace fees and shipping costs, marketers also need to account for other costs such as warehousing, product returns, free shipping discounts and marketplace campaigns to know the actual CAC (customer acquisition cost). Competition amongst e-commerce marketplaces also drives them to bring their costs down and changes in recommendation algorithms force sellers to decrease their listing costs and demand exclusivities.

 

"Digital commerce is an ecosystem and should not be considered only as a sales channel. Good customer experience and value creation can be a big driver. Value creation may sometimes be as simple as putting things together based on consumer needs. This serves as a convenience to consumers while buying, so instead of buying individual sku they can buy the brand's offerings. i.e. gift packs.  Virtual bundles allow brands to offer consumers a solution based on their needs or wants". 

‒ Satish Kunwar, Head of Digital Commerce, PZ Cussons, Indonesia

 

Creative e-commerce strategy for bottom funnel profit marginalisation

Before the pandemic, both showrooming and webrooming were much talked about and had their own preferences for specific categories. The pandemic changed the buyer journey completely to a digital one, but what has not changed is the desire for experience at each stage. In-real-life (IRL) stores are being re-imagined in the digital space with technology, with UI/UX inspired by great design thinking giving better returns over cookie-cutter solutions. 

 

“It is clear that e-commerce is an area of growth for brands. It provides brands with a new way to interface with customers to persuade and drive purchase. However, as this space develops, brands also need to evolve their thinking from being focused purely on a bottom-funnel, transactional approach, to a more holistic brand experience, focused on customer’s needs. Brands set themselves up for success if they focus on the entire experience and seek to differentiate via brand experience rather than purely focusing on discounting practices". 

‒ John Campbell-Bruce, Managing Director, Lion & Lion Indonesia

 

Here are few of the creative commerce pointers that a brand can bookmark to leverage its emotional quotient in the bottom funnel.

Customisation at scale

Brands like Nike, Fleetwood and FunkySofa have mastered this art of giving customers opportunities to customise their products. Functioning as a DTC brand from production to delivery, these brands provide an experience that gives the creative canvas to the customer while making them part of the creation process. The price premium set at the point of purchase then becomes highly valuable and customers become emotionally bonded in the transaction.

 

Redefining the transaction

At the point of purchase from a click-to-pay mindset, a more engaged path can be created with technology that translates to higher satisfaction. live streaming, social influencers as brand advocates, digital shelf optimisations (DSO) and purchase experiences that can be converted to social content by users to be shared on their own social spaces, can become critical points that deter customers from basket abandonment. Better purchase experience was cited as one of the top reasons why customers stay or switch to alternative brands in the e-Conomy SEA 2021 report by Google, Temasek and Bain & Company. 

 

Creativity as a solution

Breaking the bottom funnel into micro-moments and charting experiential touchpoints can open new avenues for the brand to look beyond transactional approach and leverage its strength. Working with the right CX platform to harness the data and insights for each opportunity can then become a creative challenge to be addressed by an idea, visual styling or value messaging. 

 

"During my time in China working with e-commerce / tech giants like JD.COM and Meituan, I've witnessed how critical it is for both brands and the e-commerce platforms to utilise creative thinking to attract consumer interest and drive purchase.  From gamification, social commerce, innovative live selling and branded entertainment; creativity coupled with knowledge of how to apply it in a digital-first, mobile-led environment will be the added firepower to fuel e-commerce success." 

‒ Cheelip Ong, CCO and CPO, Lion & Lion

 

A step before marketplace strategies, the creative approach can also be harnessed to strengthen a customer’s intent towards a brand. From informational intent to transactional intent, the right content can bolden a brand’s hold on the customer’s decision and deter competitive encroachment when the customer enters the e-commerce marketplace.

 

 Long-term impact beyond ‘Sale-Days’ optimisation

During a webinar in June 2020, when McKinsey polled US consumer-packaged-goods (CPG) executives, more than one in four respondents said low profitability was their first concern with e-commerce though the primary source of growth for them in future is from e-commerce. As e-commerce marketplaces evolve and become formidable powerhouses with scale, brands will also mature in creating their own e-Commerce platforms. However, when entering the level playing field in marketplaces, brands need the mechanism that exists in their DNA which can be used creatively to deter simultaneous price discounting. 

 

"Over the last year, we have been observing and analysing how brands are trying to enter or invest in the e-commerce space. One commonality we continuously see is a complete disconnect between what brands are trying to achieve from a branding perspective to how they act in e-ccommerce due to the channel’s extreme focus on price discounting. As a creatively driven, digital-first agency, we believe we can become a very valuable partner for these brands by ensuring the unused potential of your brand equity to remove focus on price only." 

- Fredrik Gumpel, Group CEO, Lion & Lion

 

If you are looking for a more nuanced approach to e-commerce or need help with your e-commerce marketplace strategies, content development, media or analytics, you can reach us through https://www.lionandlion.com/.

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Privacy Policy

INTRODUCTION
Lion & Lion needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the laws.

Lion & Lion may change, revise and/or amend this policy from time to time in accordance with the relevant laws. The updated version of such changes will be effective starting from the date that it is published.

WHY THIS POLICY EXISTS
This data protection policy ensures Lion & Lion:

• Complies with data protection laws and follows good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

DATA PROTECTION LAW
Data Protection Law, in general, governs how organisations, including Lion & Lion, must collect, handle and store personal information.

Data Protection Law applies regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

Each of the entities under the Lion & Lion Group adheres to its local data protection law (if any); namely;
• Malaysia – Personal Data Protection Act 2010 (PDPA)
• HK – Personal Data (Privacy) Ordinance (Cap. 486)
• Singapore – Personal Data Protection Act 2012 (No. 26 of 2012)
• Vietnam – Law on Cyber-Information Security (LCIS)
• Taiwan – Personal Data Protection Law (‘PDPL’)

In addition, Lion & Lion Group will also adhere to the General Data Protection Regulations (GDPR) when applicable (ie. when personal data is processed for activities and transactions occur within the European Union).

The General Data Protection Regulations are underpinned by six important principles. These say that personal data must:
• Be processed fairly and lawfully and in a transparent manner in relation to individuals;
• Be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Be processed in accordance with the rights of data subjects and in a manner ensuring appropriate security of the personal data

PEOPLE, RISKS AND RESPONSIBILITIES

POLICY SCOPE
This policy applies to:
• All staff of Lion & Lion
• All authorised agents, contractors, suppliers, third party service providers and other people working on behalf of Lion & Lion where they are required to use personal data collected by Lion & Lion (including but not limited to its external professional advisors and auditors)
• Any related and affiliated companies of Lion & Lion (including Lion & Lion’s intermediate owners and ultimate beneficial owner)

It applies to all data that the company holds relating to identifiable individuals. This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Any other information relating to individuals and relevant to customer surveys and/or offers
• IP addresses and cookie strings
• Sensitive data (if any)

DATA PROTECTION RISKS
This policy helps to protect Lion & Lion from some data security risks, including:
• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
• Lion & Lion will also conduct a Risk Management Plan to assess risk and mitigate harm to the data that is collected and stored. This Risk Management Plan, created by the Project Manager of any project, defines how risks associated with any project will be identified, analyzed and managed and such plan will outline how risk management activities will be performed, recorded and monitored throughout the lifecycle of the project.

RESPONSIBILITIES
Everyone who works for or with Lion & Lion has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:
• Lion & Lion’s Board of Directors are ultimately responsible for ensuring that Lion & Lion meets its legal obligations.

• The Data Protection Officer is responsible for:
- Keeping management updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Lion & Lion holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

• The Head of Operations and appointed IT Manager is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

• The marketing execution teams are responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

DATA USE AND COLLECTION
Personal data is of no value to Lion & Lion unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft. The following guidelines will govern how Lion & Lion collects and uses personal data:

• Personal data will only be used for the purposes for which they were collected.
• The purposes for which personal data are being collected will be explained to individuals. These purposes may include the following; Contractual Necessity and Compliance with Legal Obligations
• Consent should always be obtained from the individual to use this personal data for a secondary purpose.
• Individuals will be provided with the opportunity to decline to provide personal data and the consequences of refusing to provide personal data will be clearly explained to individuals.
• A visible and easy to use mechanism will always be provided to individuals to withdraw their consent for processing their personal data.
• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. Data must be encrypted before being transferred
• All data stores and laptops that hold or process personal data will be equipped with encryption software.
• Personal data processed within the EU (if any) should never be transferred to a country or territory outside of the European Economic Area unless the country or territory ensures adequate level of security and unless there is a written consent.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
• Privacy / data protection compliance should always be taken into consideration in the:
- design of new and/or redevelopment of existing systems or business processes.
- specification, procurement and testing of new items of hardware used to support business processes
- specification, design and testing of new items of software used to support business processes.

DATA STORAGE
These rules describe how and where data should be safely stored. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smartphones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Personal data will only be retained for as long as necessary for the purpose(s) for which they were collected. The following controls in place to ensure that personal data are destroyed of or transferred back to another party in a manner that prevents improper access:

Data deletion or transfer requests should be made by email, addressed to the data controller at gdpr@lionandlion.com. The data controller will supply a standard request form and will aim to address the request within 14 days.
The data controller will always verify the identity of anyone making a request before handing over any information.

DATA ACCURACY
The applicable laws require Lion & Lion to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Lion & Lion should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months and to record the status after each check.

SUBJECT ACCESS REQUESTS
All individuals who are the subject of personal data held by Lion & Lion are entitled to:
• Ask what information the company holds about them and why.
• Ask how to gain access to it, request for transfer, updates or amendments of data
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.
• Raise complaints or report any breach of data protection law
• Request for erasure of data

Subject access requests from individuals should be made by email, addressed to the data controller at gdpr@lionandlion.com. The data controller will supply a standard request form and will aim to provide the relevant data within 14 days.

The Data Protection Officer will always verify the identity of anyone making a subject access request before handing over any information.

All requests (including but not limited to data breach notification and complaints) shall be free of charge and will be recorded in the Company’s system.

DATA BREACH, COMPLAINTS AND INQUIRIES
Detailed information and guidance on data breach, complaints and inquiries procedures, can be found here.

DISCLOSING DATA FOR OTHER REASONS
In certain circumstances, Personal Data may be required to be disclosed to law enforcement agencies or authorities without the consent of the data subject.
Under these circumstances, Lion & Lion will disclose the requested data. However, Lion & Lion will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

PRIVACY CONTROL MANAGEMENT
The Data Protection Officer will conduct annual Privacy/ Data Protection Compliance Audits at a designated time between the month of July and August. Staff of Lion & Lion are required take the annual privacy and data protection training with an assessment to acknowledge the policy.

GENERAL STAFF GUIDELINES
• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• Lion & Lion will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Code Of Conduct

Lion & Lion - Code of Conduct

Scope and Objective

This Lion & Lion Code of Conduct (“Code”) embodies the guidelines and policies applicable to all employees (including but not limited to the directors, etc) of the Lion & Lion Group of Companies, in relation to the standards, ethical conduct, integrity and the highest standards of professionalism that all employees (at all levels) under the Lion & Lion Group of Companies are expected to comply with, at work and any external engagements with third parties. This Code aims to regulate and maintain order, structure and discipline among all employees to advocate industrial harmony at the workplace and during any external engagements, as well as to ensure that all applicable laws are adhered to. It is every employee’s responsibility to comply with the guidelines and policies stipulated in this Code as well as any updates or amendments issued by Lion & Lion from time to time.

This Code is not a comprehensive guide that covers every ethical situation or issue employees may face in their course of work. From time to time, Lion & Lion is entitled to update or amend this Code upon any changes in applicable laws, any changes to Lion & Lion’s internal policies, or any other relevant factors. Employees are expected to regularly visit this Code to ensure that they are properly updated and informed as to any amendments to the Code. It is also the employees’ continuous obligation to familiarise themselves with all applicable laws relating to their work responsibilities and Lion & Lion’s policies and regulations.

Employees shall refer to Lion & Lion’s People & Culture Department for clarification or guidance in any situation or circumstances not covered by this Code, or in case of any doubt. 

In relation to any violation or suspected violation of this Code, employees shall report such violation or suspected violation to the People & Culture team/Department.

The employees acknowledge that non-compliance with this Code is a grave offence and will result in disciplinary action. Non-compliance with this Code may also result in the suspension or termination of the employee, and if warranted, legal proceedings against the employee, in addition to any disciplinary action.

This Code is to be read and applied together with all other related or applicable policies and guidelines issued and may be issued by Lion & Lion.

Standards of Conduct

  • Health and Safety in the Workplace

Lion & Lion believes that a safe, clean and healthy work environment plays a major role in contributing to the happiness of the employees, and Lion & Lion is committed to providing a conducive workplace/work environment to achieve this goal. In return, employees are expected to play their role in also making sure that the workplace is safe, clean and healthy.

 

  • Treatment and Fair Practices in the Workplace

In Lion & Lion, our workplace consists of a diversified workforce and we promote equal opportunity, non-discrimination and fair treatment in all aspects of employment. We strongly believe in recruiting, developing and retaining employees based on their abilities, competency and merit. Together with Lion & Lion, the employees work together to uphold a working environment and culture where everyone is treated fairly and equally, regardless of age, religion, race, sex, ethnic origin, colour, marital status, disability, veteran status or sexual preference.

 

  • Threat, Harassment, and Violent Conduct

Lion & Lion strongly opposes any form of disrespect, harassment, threat, intimidation, violence or any other inappropriate behaviour in the workplace. It is every employee’s responsibility to report to the People & Culture team/Department any harassment, discrimination, threat, violence, and offensive or inappropriate behaviour an employee may face during his or her course of work. All complaints will be treated in the strictest confidence and shall be investigated. Upon the completion of the investigation, an appropriate action will be taken to stop and prevent such conduct. A flow chart of the complaint, reporting and investigation process can be found here.

 

  • Sexual Harassment 

Sexual harassment in the workplace is any unwelcome conduct of a sexual nature that might reasonably be expected or be perceived to cause humiliation or offense. It can be any conduct of a verbal, non-verbal or physical nature, including written and electronic communications, and may occur between persons of the same or different genders. Any employee that believes an incident or incidents of sexual harassment has taken place in the office, the employee should report this to the People & Culture team/Department. Such complaint(s) shall be taken seriously and shall be investigated swiftly and without prejudice. A flow chart of the complaint, reporting and investigation process can be found here.

 

  • Abuse of Power

The abuse of power/authority is defined as the misappropriation or the improper use of a position of power, influence or authority by a person towards others. Abuse of power can include a one-time incident or a continuous incident. Abuse of power may consist of conducts that create an abusive or a hostile work environment. Employees are requested to report any abuse of power incidents (or if they suspect that abuse of power has occurred in the workplace) to the People & Culture team/Department.

For the avoidance of doubt, decisions made through the proper use or process of managerial/supervisory responsibilities are not considered as an abuse of power/authority.

A flow chart of the complaint, reporting and investigation process can be found here.

 

  • Alcohol, Drugs, and Prohibited Substances

Lion & Lion expects its employees to perform their duties diligently and avoid any influence of any substance that could affect their job performance or pose unacceptable safety risk to themselves and others. In situations where the serving of alcoholic beverages is permitted (e.g. functions or company-sponsored activities or events), employees are expected to consume the alcoholic beverages responsibly. Employees are also expected to behave/act reasonably and responsibly as well as to comply with all relevant laws and regulations in regard to the serving and the consumption of alcoholic beverages (e.g. employees shall not drink and drive, etc).

 

  • Data Protection and Privacy Policy

Lion & Lion has put in place its privacy policy to govern and comply with the relevant and applicable data protection laws. Employees are expected to adhere to the privacy policy in the course of their work.

 

  • Confidentiality Obligations 

It is the employees’ duty to protect Lion & Lion’s confidential information from any unauthorised use or disclosure. It is also the employees’ responsibility to safeguard any confidential information of third parties that is in the employees’ possession and which the employees have access to in the course of their work. 

 

  • Records and Reporting Obligations

Lion & Lion keeps data and records collected for a duration that is in accordance with the relevant statutory and regulatory requirements. It is everyone’s responsibility to retain and store proper records of data, etc to ensure compliance with Lion & Lion’s policies, legal and regulatory requirements.

Lion & Lion believes in doing business in an appropriate way hence internal procedures and controls have been developed to ensure that. Lion & Lion has set up proper internal controls, among others, in terms of the execution of external agreements where only designated persons are authorised to execute external agreements.

 

  • Conflict of Interest

A conflict of interest exists when two or more contradictory interests relate to an activity by an individual or an institution. It is the employees’ responsibility to act in the best interests of Lion & Lion at all times, and are prohibited from misappropriating their knowledge or position gained in the course of their work or employment for any personal or private gain/advantage.

Employees are expected to disclose any potential or actual conflict of interest promptly to the People & Culture team/Department. Together with the employees, Lion & Lion shall assess and determine the existence and seriousness of the potential or actual conflict. The employees are expected to adopt the highest standard of conduct in times of doubt.

A flow chart of the complaint, reporting and investigation process can be found here.

 

  • Anti-Bribery and Anti-Corruption

Lion & Lion prides itself on being a professional organisation and is committed to acting with integrity in all its business relationships and dealings. Lion & Lion strongly prohibits its employees from offering, giving, soliciting or accepting any bribes by anyone of any third party in order to achieve any business or personal gain. Lion & Lion upholds and is committed to being in compliance with all applicable anti-bribery and anti-corruption laws. Employees are urged to report any suspicious activities to the People & Culture team/Department. A flow chart of the complaint, reporting and investigation process can be found here.

For the avoidance of doubt, the limit for any cash/gift/vouchers that can be received by employees is capped at USD50 per gift and an annual limit of USD250. Any amount that is more than the allowed limit should be declared to the People & Culture team/Department.

 

  • Money Laundering

Money laundering can be defined as the process of concealing the proceeds of illegal activities or the act of converting or trying to make the sources of their illegal funds look legitimate (e.g. converting “dirty” money to a legitimate source of income or asset). 

Employees are expected to be aware of the applicable anti-money laundering laws and should ensure that they are adequately and appropriately informed of any developments in the laws with regard to money laundering. Employees should always ensure that business dealings are conducted for legitimate business purposes, with customers who/that are reputable, and with funds that are legitimate. It is the employees’ responsibility to be mindful of the risk of Lion & Lion’s business being used for any money laundering activities and to report any suspicious activities to the People & Culture team/Department.

A flow chart of the complaint, reporting and investigation process can be found here.

 

Whistleblower

Any employee who has any knowledge of, or suspects, any violation of this Code is encouraged to report his or her concerns through our holding company’s (Septeni) Whistleblower Hotline. Matters that may be the subject of whistleblowing and consultation using the Hotline include (but are not limited to); 

  • Conducts that violate any law;
  • Conducts that violate any internal rule of the Lion & Lion;
  • Conducts that violate corporate ethics, or any other corrupt practice.

Any complaints or disclosure shall be made to the following email address: septeni-hotline@jurists.co.jp

Further information on the process (ie. investigations, etc) can be seen in Septeni’s Hotline Handbook.

 

Review of the Code of Conduct

Compliance with this Code will be monitored closely by the management of Lion & Lion and it’s designated person(s). This Code will be regularly reviewed to ensure that it continues to remain relevant and up to date in accordance with all applicable laws and regulations.

 

This Code of Conduct is approved by;

 

Fredrik Baek Gumpel

CEO