Group of Sumitomo Bakelite Co., Ltd. - Code of Business Ethics and Conduct
We have established the “Group of Sumitomo Bakelite Co., Ltd. - Code of Business Ethics and Conduct”, which is an explanation of the above five items defined in the "Our Code of Conduct" and a more detailed standards of conduct for the five items defined in the "Our Code of Conduct". We distribute booklets containing these to the directors, officers and employees of our Group.
Group of Sumitomo Bakelite Co., Ltd. - Code of Business Ethics and Conduct (Excerpted version)
1. We provide products and services designed from the viewpoints of social benefit as well as customer satisfaction on which we place highest priority.
[The more detailed standards of conduct]
We embrace the fundamental principles of Customer First and Quality First. We put our best efforts in our tasks all the time and take proactive* actions as one and united Group of Sumitomo Bakelite Co., Ltd. in case any event or incident related to our business should occur irrespective of the place of occurrence.
||We develop and provide, at appropriate prices in a timely manner, new products which design in needs of customers and markets captured by a forward-looking way and can be used with a sense of satisfaction and security.
||We set up and implement schemes and rules on the basis of the philosophy of “Quality Assurance at Each Process”, so that we can contain quality risks in advance and achieve Zero Defect*.
||We do not ship out any product that does not meet product standards established previously. We also do not use any of materials for use in our products that does not satisfy quality standards.
||We follow the Standard Operating Procedures for manufacturing products and revise them when any fault or unclear description is found in them.
||We carry out periodical auditing of partner companies' production lines as well as our own so that we can assure appropriateness of the production.
||We act according to the spirit of “Acknowledge within a day and Respond within a week”.
- “Proactive” means to capture potential changes in customers’ products, markets and society in advance, and to take actions before an actual change or event occurs and/or somebody tells us to take actions.
- “Zero Defect” means our quality assurance activity target not causing any single event of defect or fault in customers products using our products regardless of the number of our products shipped out to them, be it one million pieces or one hundred tons in volume.
2. We endeavor to improve business performance of the Group of Sumitomo Bakelite Co., Ltd. from a global perspective.
[The more detailed standards of conduct]
||We share and mutually recognize Our Group strategy within Our Group to perform tasks, to produce synergy in the group and to gain a maximum result as a group.
||We honor and respect culture and values of different countries and regions, and pay due consideration to religious events and customs.
3. We observe corporate ethics, abide by all applicable laws and regulations as well as our internal rules, and, above all, value fairness and transparency in our business activities.
[The more detailed standards of conduct]
||Compliance with competition laws (anti-trust laws)* and fair transactions
- We abide by all regulations on transactions in the applicable competition laws, and perform business activities based on the rules of free, fair and transparent competition.
- We do not make agreement or exchange information on sales terms such as selling prices, volume and buyers of products and services which may violate the applicable competition laws (anti-trust laws) of competitors and nations. And also, we do not participate in such meetings as there are possibilities that agreement is made which may influence sales terms such as selling prices, volume and buyers of products and services.
- We comply with all applicable laws and internal rules about advertisement and public relations activities as well as sales activities of our companies, products and services. We avoid and do not use any inappropriate expressions and representations in these activities in view of sound social norms.
- Competition laws (anti-trust laws) differ from nation to nation. Some countries such as U.S., EU and China are widening the scope of application of their competition laws (anti-trust laws) to extraterritorial jurisdictions (i.e. application of their national laws and regulations to the events and incidents which occur outside their jurisdiction). We have to read carefully all applicable competition laws (anti-trust laws) of the nations where we operate and also the internal competition and anti-trust rules of Our Group companies outside Japan. In the case these competition laws and rules are more stringent in terms of obligations and procedures than this handbook above, we have to follow the most stringent laws and rules among all.
||Prohibition of commercial bribery/restriction on gifts and entertainment*
- We do not give to and receive from government officials and directors of state-owned companies any gifts, entertainment and other benefit and do not behave or act in such a way as appears to be for the purpose of obtaining favorable business interest.
- When we make donations and political donations, we follow applicable local laws and regulations as well as applicable internal rules and policies set forth by each of Our Group companies. We do not conduct any action which may be misunderstood as bribery or collusion with government or administrative agencies.
- We do not request any payment or gift from our business partners with no reason.
- When we give to or receive from our business partners gifts, entertainment and other benefits, we will be careful enough to see if they are excessively expensive in ordinary social norms and business practices.
- When gifts, entertainment and other benefits offered by business partners are excessively expensive in ordinary social norms and business practices, we decline such offer.
- Restrictions and prohibitions of gifts and entertainment vary from country to country, and are getting stricter every year. For example, the USFPCA is now applicable in some jurisdictions outside the U.S. (the territorial scope of application of the FPCA is larger than the U.S. territory). We have to read carefully the applicable laws and regulations on commercial bribery of the nations where we operate and the internal rules and policies set forth by each of Our Group companies and follow the most stringent laws and rules among all.
||Corporate assets, Personal conflicts of interest
- We do not take any action which may impair the value of our corporate asset, tangible or intangible, (such as land, buildings, facilities, equipment, products, office machines, cash and deposits, negotiable securities) through illegal or personal use of them.
- We do not take any action which may impair the interest of Our Group by pursuing interest for our own selves and/or a company for which we, as an individual, act as representative or representative director. For example, transactions for our own interest as an individual with a company which our family members or relatives are running, and purchase of Our Group’s assets under terms of condition favorable for us as an individual.
- We do not conduct any unfair transaction for the purpose of receiving unfair benefit for our own selves as an individual.
||Correct and accurate records and reports, appropriate disclosure of information
- We make correct and accurate records and reports of business activities based on the facts. We do not conduct any false or imaginary recording or reporting.
- We disclose information on financial settlements in a timely, compliant and accurate manner.
- We disclose any Our Group’s corporate information which may influence Our Group’s business performance in a timely, compliant and accurate manner.
||Compliance with laws and regulations related to import and export
- We comply with all applicable laws and regulations concerning security and trade control and the internal rules set forth in line with them so that Our Group’s technologies and products provided and exported will not be used for any activity related to development and manufacturing of conventional weapons and mass destruction weapons which may threaten international peace and security.
- We comply with other laws and regulations related to import and export as well, and do not make any false declaration of items for international transactions.
||Control and management of information
- We recognize the value of Our Group’s confidential information and also the confidential information disclosed by others. We handle and control such confidential information properly and appropriately in accordance with all applicable laws and regulations, agreements and internal rules and policies, so that none of such confidential information may be leaked and cause any damage to Our Group or others and violate relevant laws, regulations and agreements.
- We take procedures necessary for disclosing confidential information of our companies to others, including conclusion of confidentiality agreement.
- We obtain confidential information owned by others only when it is imperative to do so for carrying out our company’s business. The method of obtaining such confidential information must be fair and appropriate in view of the impartial business practices.
- We recognize the importance of protecting personal information and handle any personal information properly in accordance with the policy on personal information protection established by each of Our Group companies.
- We pay due attention to cyber attacks which are getting more sophisticated and ingenious, and try to use up-to-date information equipment and devices to avoid any leakage of information by cyber attacks.
||Intellectual property rights
- We protect, control and use patents, knowhow, and other intellectual properties which were created in the course of Our Group’s business activities.
- We proactively take actions not to infringe others’ intellectual property to avoid any disruption of its business. We carry out thorough search and investigation of others’ intellectual property before we initiate research, development, design, production, sales of new products and technologies, take necessary measures if there is any doubt of infringing others’ intellectual property rights.
- We properly use the company names (trade names), the product names (trade marks), and others as important company assets, and makes effort to eliminate unlawful use of these assets by others.
||Prevention of insider trading*
- We do not trade in shares or other securities of our own companies or others’ from the point of time when we come to know non-public information which may impose material influence on the price of such shares or other securities of our own company or others’ until such information is publicly announced and released.
- We do not disclose non-public information which may impose material influence on the share price of our own companies or others’ from the point of time when we come to know such non-public information until such information is publicly announced and released.
- Insider trading: Any person related to a company trades in shares and other securities by him/herself or through a third person related to him/her by using such information as he/she has come to know in the course of his/her business activities or non-public information of his/her company or others’.
||Prevention of money laundering and ban on any relations with criminal organizations
- We comply with laws and regulations of relevant countries and regions which restrict money laundering (legitimization or washing of illegally obtained money through crimes, etc.)
- We do not accept any undue request from any criminal organization. We will be careful enough not to get involved in any transaction with any criminal organization.
4. We place importance on safety, and voluntarily take actions for environmental protection.
[The more detailed standards of conduct]
We participate, through our daily operations, in the following activities of the Group of Sumitomo Bakelite Co., Ltd. related to safety and hygiene, environmental protection, chemical substance management, and disaster prevention.
||Promotion of safety and health
- Our Group always keeps in mind “Safety comes first of all,” and makes best efforts to prevent labor accidents.
- Our Group complies with all laws and regulations related to occupational safety and health.
- Our Group carries out risk assessment of design, machine and work in accordance with the guideline on comprehensive safety standards for machinery to assure built-in safety of the equipment, and strive to prevent labor accidents.
- Our Group carries out risk assessment of chemical substances such as raw materials, reagents, products and others, and handle them carefully.
- Our Group promotes safety and health activities through mutual cooperation between labor and management.
- Our Group conducts periodical inspections including safety and health patrols. Our Group makes improvements immediately in case any issue is identified by the inspection, and makes effort to create a safe and comfortable work environment.
||Promotion of environmental protection
- Our Group sets a mid- to long-term target for environmental load reduction, implements the following measures systematically to achieve the target, and contributes to realizing a sustainable society:
- reduction, separation and collection of waste,
- reduction of emissions of carbon dioxide and chemical substances,
- saving of energy and resources, and
- reduction of material flow cost (negative cost of products).
- Our Group strives to develop environment-friendly products (which do not contain hazardous or harmful substances, do not require use of hazardous or harmful substances at customers, and are easier for recovering and recycling resources contained).
- Our Group implements internal education, training, and promotion activities on environment, and enhances the Personnel’s awareness of environmental issues.
- Our Group observes laws, regulations and regional agreements relevant to Our Group’s products, services and activities.
- Our Group positively takes actions for environmental protection, and contributes to preservation of biodiversity.
||Management of chemical substances
- Our Group establishes a system to cope with expansion of stricter laws and regulations on chemical substance management on a global scale, minimizes risks of violating regulations on chemical substances, enhances the level of chemical substance management, and thereby contribute to improving customer satisfaction.
- Our Group complies with laws, regulations and regional agreements related to chemical substances.
||Prevention of fire and disasters
- Our Group carries out inspection of fire distinguishing equipment and provides trainings on fire and disaster prevention as stipulated by the Fire Services Act and as set out in the firefighting plan prepared at each of Our Group companies and plants. Our Group improves the awareness on the importance of fire and disaster prevention among the Personnel, and makes effort to prevent accidents.
- Our Group prepares and installs equipment necessary to minimize the damage in case of accidents such as fire and explosion, natural disasters such as earthquake and damage by storm and flood, and spill of hazardous and harmful substances. Our Group also carries out evacuation drills, fire drills and first-aid drills, sets up an emergency call network, and prepares necessary items.
- Our Group carries out risk assessment on fire, explosion and spill, and takes necessary preventive measures to minimize disaster risks.
- Our Group makes and implements BCPs which cover raw material procurement, production through distribution, so that we will not cause any disruption in our product supply flow for customers.
5. We honor and respect each individual’s personality and rights, and make efforts to create amicable and lively workplaces.
[The more detailed standards of conduct]
||Respect for human rights
- We honor and respect human rights and each individual’s personality. We treat all the Personnel without discrimination based on their race, religion, nationality, age, sex, thoughts, belief, academic records, health condition, and others.
- We do not allow any violence and harassment in the work place.
- We abide by local laws and regulations of each country and region where we operate when hiring employees. We do not allow child labor, a practice that forces children under the minimum age for work set forth by each country and region where we operate to work. We also do not force employees to conduct unreasonable labor against their will.
||Creation of friendly workplace
- We make efforts to maintain and improve a good labor and management relationship, and to create a comfortable workplace through mutual cooperation between labor and management.
- We, at each of our workplaces, create an environment which allows free and candid opinions to be expressed about work tasks, workplace culture, human resource development among others.
- We treat our colleagues as an individual on an equal footing and respect each other as a business partner.
- We support work-life balance of the Personnel by positively using various schemes and systems for promoting different ways of working and for adopting different types of leave of absence. We also take good care of and support such Personnel as are facing pregnancy, delivery, nursing of their family members, and other difficulties.