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, including Environmental Compliance and Socioeconomic Compliance. In fiscal 2021, the Compliance Committee met three times to examine the appropriateness of the whistleblower system and discuss future issues, review the contents of the Group’s anti-bribery policy and basic regulations, and review Our Code of Conduct.

Compliance System

Code of Conduct for Employees

We have established Our Code of Conduct, a code of conduct enabling Group to carry out its business activities without error, as well as the Code of Ethics for the Group of Sumitomo Bakelite Co., Ltd. a specific code of ethics and conduct from the perspective of compliance with laws, regulations and corporate norms to be adhered to by Corporate Officers and employees of each Group company in the execution of their duties. The content of Our Code of Conduct and of the Code of Ethics for the Group of Sumitomo Bakelite Co., Ltd. is disseminated among Group Directors and employees through education at the time of hiring, education during compliance emphasis month in October every year (e-learning or reading in rotation in the workplace), and other means.

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 four- frame 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 (cartoon character)

Mamoru-kun (cartoon character)
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.

Internal Whistleblower System

We have established an internal whistleblower system (which has been designated the “Compliance Whistleblower System” at our Group). Under this system, employees can report to an internal contact point (GM of the Internal Audit Department) or an external contact point (Legal Counsel) when they have discovered a compliance violation or suspect there may have been such a violation, in an effort to promptly detect and preemptively prevent compliance violations. In addition to Group Directors, Officers, and employees, Group stakeholders (including retirees, applicants for employment, and business partners) may also report incidents. The privacy of the informant is strictly protected to ensure that the informant will not be disadvantaged as a result of the report. In fiscal 2021 there were three cases reported to the Compliance Whistleblower System. The results of our investigations revealed that there were no major violations to laws and ordinances, such as violations to laws against child labor, forced labor, accounting fraud, bribery or corruption, or the Antitrust Act, nor were there any cases that could have a significant negative impact on society. All of these cases were dealt with appropriately.

Moreover, some of our group companies have established their own unique internal whistleblower systems, which are distinct from our shared Compliance Whistleblower System, by taking into consideration of the factors such as the legal requirements of the country in which they are located, their company size, and so forth. In fiscal 2021 there were 3 cases reported to these unique internal whistleblower systems at these group companies. The results of investigations revealed that there were no major violations to laws and ordinances, such as violations to laws against child labor forced labor, accounting fraud, bribery or corruption, or antitrust laws, nor were there any cases that could have a significant negative impact on society. All of these cases were dealt with appropriately.

Compliance whistleblower system response process flow

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, 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 its 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 2021, 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.

Anti-Corruption Policies and Initiatives

We have has established the Anti-Bribery Policy of Group of Sumitomo Bakelite Co., Ltd. and the Basic Rules and Regulations for Bribery Prevention for Group of Sumitomo Bakelite Co., Ltd. thereby establishing standards of conduct and compliance for Officers and employees, as well as a zero-tolerance approach to bribery and extortion of benefits. We advance anti-bribery initiatives based on the anti-bribery laws and regulations in the countries where our group companies are located, and the level of bribery risk in each country and business field.

Furthermore, the Code of Ethics for Group of Sumitomo Bakelite Co., Ltd. prohibits corrupt acts such as embezzlement, breach of trust, money laundering, and insider trading which constitute abuse of authority or position in one’s duties for personal or organizational gain.

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