Compliance

Compliance System

We emphasize compliance because we recognize that adherence to laws and corporate ethics is integral to the conduct of business.
We established the Compliance Committee to minimize the risks of compliance violations at our Group, promote the creation of structures for compliance, and to promote activities to raise awareness of compliance.

Code of Conduct for Employees

We make efforts to inform our employees of our Business Philosophy in which our business principal is shown, and Our Group's Code of Business Ethics and Conduct, such as by offering e-learning on a regular basis or having employees read this aloud from pamphlets in their workplace. Our Group's Code of Business Ethics and Conduct is consist of specific standards of conduct and explanations for Our Code of Conduct, which was enacted to serve as standards of conduct that our officers and employees must adhere to when carrying out their duties.
The current version of Our Group's Code of Business Ethics and Conduct was revamped in October 2017, taking into account our measures for CS promotion, SBPS, quality control, health and safety, as well as the latest worldwide trends in legal compliance. It has also been translated into seven languages.

The booklet on Our Group's Code of Business Ethics and Conduct

Articles for Emphasis in Compliance

Workplaces in each department apply compliance to daily operations, decide on the key items for compliance and each prepare Articles for Emphasis in Compliance. Although the Articles differ among workplaces, they are displayed prominently and confirmed with all employees periodically by having them read aloud in unison. Our group companies, in Japan and overseas, also undertake similar activities.

Compliance Education Using Cartoons

Every month, our internal publication contains a fourframe cartoon about compliance under the title “The Way to Become a Compliance Master.” This cartoon explains compliance in an easy-to-follow style. Past cartoons have been compiled into two booklets, which were distributed to employees to raise awareness of compliance.

Mamoru-kun joined the company 18 years ago. He’s a very active mid-level employee, and everyone relies on him. Mamorukun 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.

"Compliance Reporting System" of Group of Sumitomo Bakelite Co., Ltd.

Introduction

To detect and prevent non-compliance at an early stage, Group of Sumitomo Bakelite Co., Ltd. (Our Group) has introduced a whistleblowing system (known as the Compliance Reporting System in our Group that allows you to report non-compliance or the threat of non-compliance to an internal whistleblower contact or external whistleblower contact.

Summary of Compliance Reporting System

What can be reported to this "Compliance Reporting System"?

Act or omission that violates laws, company rules, or "Code of Business Ethics and Conduct of Group of Sumitomo Bakelite Co., Ltd.", or act or omission that may lead to such violation

Who can use this "Compliance Reporting System"?

  • All directors, officers, employees (including part-time staff, contract workers, temporary workers) in group companies of Sumitomo Bakelite Co., Ltd.
  • Stakeholders of group companies of Sumitomo Bakelite Co., Ltd. (including retired employee, applicants for employment, and business partners)

Who are the "Reporting Contacts"

You can choose to report to either of the following Reporting Contacts.

  • Internal Reporting Contact
    General Manager, Internal Audit Dept. of Sumitomo Bakelite Co., Ltd.

    E-mail compliance@ml.sumibe.co.jp
    (This E-mail will be automatically forwarded only to General Manager, Internal Audit Dept.)
    Address 5-8, Higashi-Shinagawa 2-Chome, Shinagawa-Ku, Tokyo 140-0002, JAPAN
  • External Reporting Contact
    Tamiya Gohdoh Law Office
    Attn: Attorney-at-law in charge of "Compliance Reporting System" of Sumitomo Bakelite Co., Ltd.

    E-mail bcl60683@nifty.com
    Address Tokyu Land Corporation Akasaka Bldg 11F 14-3, Nagatacho 2-Chome Chiyoda-Ku, Tokyo, 100-0014, JAPAN

How can you contact Reporting Contact for "Compliance Reporting System"?

  • If you need to use this "Compliance Reporting System", you can fill out "Compliance Reporting Form" (please download from below link) and send it to Reporting Contact by e-mail or mail.
  • You can also make a report anonymously. However, we recommend that you make a report under your own name. This is because anonymity limits the ability to investigate and take corrective action.

Receipt, reporting, investigation, etc.

  • Upon receiving whistleblower's report, Reporting Contact will report it to:
    - Chairman of Compliance Committee of Sumitomo Bakelite Co., Ltd.; and
    - General Manager of General Affairs Division of Sumitomo Bakelite Co., Ltd.
    Thereafter, Chairman of Compliance Committee directs an Investigation Team consisting of members of the relevant departments to investigate the incident and consider countermeasures.
  • If any of Reporting Contact, Chairman of Compliance Committee, General Manager of the General Affairs Division, or member(s) of the Investigation Team has an interest in the incident that is the subject of the above investigation, he/she will be excluded from the above reporting or investigation.
  • Except in cases where whistleblower cannot be contacted due to anonymous reporting or other due reasons, whistleblower will be will be informed of the receipt of reporting, the results of the investigation and the measures to be taken.

Confidentiality

  • Reporting Contact, Chairman of Compliance Committee, General Manager of the General Affairs Division, or member(s) of the Investigation Team will not share or disclose any information that may lead to the identification of whistleblower(s), except for the minimum number of people deemed necessary for the investigation and taking corrective measures. In addition, they will not use such information for any other purpose than the necessary for the investigation and taking corrective measures.

Prohibition of searching and detrimental treatment

  • Searching for the identity of the whistleblower is strictly prohibited.
  • Detrimental treatment (for example, dismissal, disciplinary action, demotion, pay reduction, detrimental reassignment/secondment/transfer, recommendation to resign, refusal to renew a labor contract, and de facto harassment) of the whistleblower and/or anyone who cooperates with the investigation is strictly prohibited for his/her making a report or cooperating with an investigation.
  • Any officer or employee of our Group who violates the above prohibition matters will be disciplined in accordance with each company's labor regulations and/or other internal rules governing disciplinary action.

Prohibition of reporting for fraudulent purposes

  • Reporting for the purpose of fraud (e.g., false reporting or reporting for the purpose of defaming others) is strictly prohibited. On the other hand, our Group will not take advantage of the above to prevent reporting for non-fraudulent purposes.
  • Any officer or employee of our Group who violates the above prohibition matters will be disciplined in accordance with each company's labor regulations and/or other internal rules governing disciplinary action.

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