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Compliance

We are committed to various group-wide initiatives intended to further improve and strengthen compliance systems in accordance with our Corporate Code of Compliance.

Compliance structure

In order to reinforce our compliance, our Board Meeting has established group-wide compliance policies, “Nippon Shokubai Code of Conduct” and the other codes of conduct, and the executive officer responsible for compliance has decided medium- to long-term and annual action plans. Under the supervision of the executive officer responsible for compliance, the Legal Department promotes various group-wide initiatives for the entire Group including affiliated companies.

Activities to improve compliance

Rank-based training (Group-wide program)

We provide training courses on corporate ethics targeting three specific employee ranks: managerial employees, mid-level employees, and rank-and-file employees (including entrusted workers and workers dispatched from temporary agencies). We require all employees to attend a training course at least once every four years. In fiscal 2019, we organized Group-wide corporate ethics training courses targeting employees in managerial positions of our nine Group companies in Japan, in addition to managerial employees of the Company. A total of 33 training courses were held, in which approximately 740 employees; around 500 managerial employees of the Company and around 240 employees in managerial positions at Group companies, participated.
In these training courses, trainees first reviewed the lessons of the rank-based corporate ethics training they had received and confirmed the key points in preventing misconduct. After that, they discussed in groups their awareness of preventing power harassment as managers and their decision-making criteria for "gray-zone" corporate ethical matters, thereby confirming the perspectives they should have as managers. Through these training courses, we aim to help enable the employees in managerial positions in our Group to more properly instruct their subordinates and create workplaces where misconduct can hardly occur.

Awareness initiatives in the workplace

To ensure the penetration and adoption of compliance throughout the workplace, we conduct compliance training courses for each workplace once every six months. This training has become a forum for active discussion within each workplace based on a training program that covers violations of corporate ethics and legal violations and similar actions prepared based on situations that actually arose in other companies. We have been implementing this program at our Group companies in Japan since January 2018.

Corporate Ethics Guidebook distribution


Nippon Shokubai
Corporate Ethics
Guidebook

Nippon Shokubai Group
Corporate Ethics
Guidebook

We have prepared the Nippon Shokubai Corporate Ethics Guidebook, and we distribute it to our employees and revise it as appropriate. We have also prepared the Nippon Shokubai Group Corporate Ethics Guidebook for our Group companies in Japan, and we distribute it to the employees in each company. The content of these guidebooks serves to increase individual awareness of compliance and supports learning activities. The books include behavior guidelines that should be followed not only in daily work but also in private life, commentaries and a Q&A section, for example. They are also effectively used for employee training.

Awareness activities on our portal


Portal “Understandable Corporate Ethics”

Our corporate intranet hosts a portal titled "Understandable Corporate Ethics." It lists various kinds of manuals including the manuals as to basic information on contracts, competition laws in various countries, observance of anti-bribery laws and subcontract law, links to websites covering related laws and regulations, and a FAQ page. This site presents the latest available information, and it is updated whenever the relevant laws and regulations are revised.

Whistleblower System

As part of our initiatives to implement compliance, we have established the Whistleblower System under which facts or suspicions of compliance violations inside the company can be freely reported to the internal reporting desks we have set up both inside and outside the company. The intention of the whistleblower is always respected in determining whether or not to disclose the details of the information and the name of the whistleblower, with the objective of protecting the whistleblower.

Compliance with Anti-Bribery Laws and Competition Laws

For Compliance with Anti-Bribery Laws ( Nippon Shokubai Group's Code of Conduct )

Nippon Shokubai Group Companies strictly prohibit any corruptions in breach of applicable laws in our business activities.
In order to express and give shape of such group policy, we adopt the group code of conduct, which all the individuals working for Nippon Shokubai Group Companies should comply with.
Group Code of Conduct

For Compliance with Competition Laws ( Nippon Shokubai Group's Code of Conduct )

Nippon Shokubai Group Companies will conduct all business transactions based on free and fair market competition principle.
In order to express and give shape of such group policy, we adopt the group code of conduct, which all the individuals working for Nippon Shokubai Group Companies should comply with.
Group Code of Conduct