Compliance

Basic Approach and Policy Related to Compliance

Our Group recognize that it is extremely important to compliance with laws, regulations and corporate ethics when conducting business activities, and therefore our group pursues management that emphasizes compliance. We have established the “Our Code of Conduct”, which enables the Group to carry out its business activities with integrity, as well as the “Code of Ethics for the Group of Sumitomo Bakelite Co., Ltd.”, as a specific code of ethics and standards of conduct from the perspective of compliance with laws, regulations, and corporate ethics to be observed by our Group’s directors, officers and employees in the course of business. The content of “Our Code of Conduct” and of the “Code of Ethics for the Group of Sumitomo Bakelite Co., Ltd.” is disseminated among our Group’s directors, officers and employees through the training at the time of hiring, training during the “compliance emphasis month” in October every year (e-learning or reading in rotation in the workplace), and other means.

Please see the links below for the contents of major compliance policies such as "Our Code of Conduct" and " Code of Ethics for Group of Sumitomo Bakelite Co., Ltd."; and please see the "Data on Compliance" section of this page for the information on compliance training results.

Compliance System

We established the “Compliance Committee” to minimize the risks of compliance violations at our Group, promote the creation of structures for compliance, and promote activities to raise awareness of compliance. In fiscal 2022, the Compliance Committee met three times to establish the Code of Ethics for Group of Sumitomo Bakelite Co., Ltd., revise the whistle-blowing system based on revision of the Whistleblower Protection Act of Japan, and examine the appropriateness of the whistle-blowing system and discuss future issues.

compliance chart

Compliance Slogans

At each department's workplace, we have established “Compliance Slogans'', which are important compliance-related items that are appropriate for each department's daily work. These items may differ for each department, but we strive to make employees aware of them by posting them in the workplace and having them recite them regularly. Similar initiatives are also being undertaken at our domestic and overseas affiliated companies .

Compliance awareness using comics

Our monthly in-house newsletter contains an article titled “The Way to Become a Compliance Master! ‘’ This is an easy-to-understand explanation of compliance based on a 4-panel comic, and we have also published two booklets summarizing the serialized articles so far. These booklets are distributed to employees and used for compliance awareness.

manga character Mamoru

Mamoru-kun He’s a very active mid-level employee, and everyone relies on him. Mamoru-kun is able to offer appropriate advice throughout the company as a compliance master, which is especially appreciated given the spate of corporate scandals hitting Japan recently.

Whistle-blowing System

We have established a whistle-blowing system (which has been designated as the “Compliance Reporting System” at our Group). Under this system, those who find compliance violation or suspect there may have been such a violation can report to an internal contact point (GM of the Internal Audit Department) or an external contact point (Legal Counsel), in an effort to promptly detect and preemptively prevent compliance violations. In addition to our Group’s directors, officers and employees, our Group’s stakeholders including those who have left the company, those going through the recruitment process, and business partners can also report incidents. The privacy of whistleblowers is rigorously protected to ensure that they are not placed at a disadvantage as a consequence of reporting violations.

Moreover, some of our Group companies have established their own unique whistle-blowing systems, which are distinct from our group-wide “Compliance Reporting System”, by taking into consideration factors such as the legal requirements of the country in which they are located, their company size, and so forth.

Please see the link below for more information on the “Compliance Reporting System”, and please see the “Data on Compliance” section of this page for the information on results and responses under the whistle-blowing systems .

Monitoring

In accordance with the “Basic Policy on Internal Control Systems”, the “Internal Auditing Regulations”, the “Basic Rules and Regulations for Internal Control over Financial Reporting”, the “‘Monozukuri’ Auditing Regulations”, the “Security Trade Control Regulations” and other company regulations, the Internal Audit Dept., Corporate EHS Promotion Dept., Corporate General Affairs & Legal Dept., and other departments involved in internal auditing audit and assess the compliance of the Company and our Group companies, both in Japan and overseas.

This is done mainly by means of site audits, at the actual sites, and written audits, via inspections of the results of self-audits, by the departments being audited. Audits and assessments are conducted with monitoring from the standpoint of whether the operations of departments are in compliance with relevant laws and conform to various standards.

Departments where issues are identified are required to submit written reports detailing actions taken to resolve the issues. In fiscal 2022, auditing and assessment was conducted from the standpoints of environment, human rights, occupational health and safety, provision and use of products and services, management of customer information and data, proper accounting, and fair trade, with no significant violations of laws or regulations.

Data on Compliance

  Coverage Results in FY2022 Results in FY2023
Compliance training participation rate(%)*1 Group *3 Total Participation Rate: 74.5%
(Number of participants: 6756)
Participation Rate: 100%
(Number of participants: 8740)
Group companies located in Japan (including Sumitomo Bakelite Co., Ltd.) Participation Rate: 98.7%
(Number of participants: 3694)
Participation Rate: 100%
(Number of participants: 3616)
Group companies located in the countries other than Japan Participation Rate: 57.4%
(Number of participants: 3062)
Participation Rate: 100%
(Number of participants: 5124)
Number of whistle-blowing cases (numbers per year)*2Group *3 Total 12 (Aggregation no completed)
Compliance Reporting System (Group-wide whistle-blowing system) 4
Whistle-blowing system established independently by subsidiaries 8
  • *1 As part of activities during Compliance Enhancement Month, we implemented e-learning or in-workplace training for the officers and employees of group companies (including Sumitomo Bakelite Co., Ltd. ), where they learn about the contents of Our Code of Conduct and Group Code of Ethics (which includes prohibition of corruption, prohibition of cartels, prohibition of discrimination and harassment), the overview of the whistle-blowing system, and the Compliance Slogans.
  • *2As a result of investigations, there are no cases that seriously violate laws and regulations or have a significant negative impact on society, such as human rights violations (child labor, forced labor, etc.), accounting fraud, corruption (bribery, breach of trust, money laundering, etc.), violations of antitrust laws, etc. All whistleblowing were dealt with appropriately.
  • *3 Sumitomo Bakelite Co., Ltd. and the companies in which Sumitomo Bakelite Co., Ltd. directly or indirectly holds more than 50% of the voting rights.

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