We, the Sanyo Chemical Group, declared in our Code of Corporate Ethics that it is essential corporate behavior to ensure legal compliance and to fulfill corporate social responsibility, which has been implemented to take the lead in the realization of a sustainable society. With good sense and integrity, we are committed to improving our society and are following our company mission, “Establish a better society through our corporate activities.”
Internal Compliance System
We have appointed a Director in charge of corporate ethics and established the Compliance Committee, which is under the direct control of the Board of Directors.
The Compliance Committee is a deliberative and decision-making body on the basic policy and measures regarding compliance. The committee holds regular meetings. In FY2023, the committee studied the content to be learned by employees at corporate ethics study meetings, which are held on a company-wide basis, identified important risks that can be reduced through compliance activities, and formulated countermeasures.
We have also set up the Internal Audit Office under the direct control of the President, so as to strengthen our internal auditing function.
Compliance Promotion Structure
Internal auditing
The Internal Audit Office conducts internal auditing. It objectively inspects and evaluates the business management and operation systems and the business performance status in terms of legitimacy, effectiveness, and efficiency. Based on the results, it makes proposals for improvement or corrective recommendations to facilitate the company’s sound management and sustainable development.
Education and awareness-raising activities
The Advice on Compliance and the Code of Conduct for Employees establishes specific criteria on daily behavior for employees.
Corporate ethics study sessions
The Sanyo Chemical Group annually holds corporate ethics study sessions in all departments to prevent the occurrence of corporate misconduct. Recently, these sessions have placed particular focus on the kind of corporate culture behind corporate misconduct to learn how corporate culture reform leads to improved compliance. Taking seriously the fact that four cases of harassment occurred within the Group in FY2022, we held study sessions on harassment in FY2023. The sessions consisted of three parts: online training to learn about harassment, check the questionnaire survey to understand the actual situation, and group discussions. A total of 1,528 people participated. After the sessions, a questionnaire survey was conducted to evaluate the Group’s overall compliance activities, with a view to reflecting the results in education activities in the following fiscal years.
Legal consultant program
Employees of the Legal Affairs Dept. offer legal consultants for Group employees in Japan. They give lectures on various themes. Personnel in charge of the Legal Affairs Dept. are designated as contact persons for respective organizations (including business divisions, and subsidiaries and affiliates). Employees of the Legal Affairs Dept. visit respective business sites in Japan and offer legal consultation services “visiting legal services”. Such arrangements make it easy to seek legal advice.
Training Content for FY2023
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| Contents | Target group |
|---|---|
| Contract Basics | Employees in their first to fifth year of employment |
| Antimonopoly Act (Restriction of Trade and Business Alliance) | Sales staff |
| Prevention of Fake Contracts | Employees working with subcontractors |
| Export Trade Control Order | Research staff |
| Industrial Waste Disposal Consignment Agreement | Employees involved in the conclusion of industrial waste disposal consignment contracts |
| Non-Disclosure Agreement (NDA) | Employees involved in the signing of non-disclosure agreements |
| Technology licence agreement | Mid-career employees |
| Subcontract Act | Employees working with subcontractors |
| Copyright | All employees |
Whistleblowing system
When an employee is aware of a compliance issue, the basic rule is to discuss it with their supervisor or the personnel concerned. If the issue cannot be resolved, the employee can use whistleblowing contact points (such as the compliance hotline) that conform with the Whistleblower Protection Act. The internal contact point is the Director of the Internal Audit Office, who serves as the Compliance Committee Secretariat, while an external contact point is a corporate lawyer. We operate the regulation requiring that the whistleblowers’ confidentiality be carefully protected to prevent their identification.
In April 2023, we opened a consultation desk for harassment in addition to the whistleblowing contact points, working to create a system that makes it easier for whistleblowers (consultants) to use these services.
Harassment Whistleblowing/Consultation Services (internal/external)
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| Compliance hotline | Whistleblowing | Internal | Internal Audit Office Senior Manager |
|---|---|---|---|
| External | Corporate lawyer | ||
| Internal consultation desk for sexual harassment, maternity harassment, and LGBT (harassment) | Consultation | Internal | Personnel Dept. |
| Harassment consultation desk LGBT consultation desk |
Consultation | External | Outside specialized institutions |
In FY2023, the number of hotline uses was one in total, and it concerned harassment.
We investigate facts with the utmost care to ensure that whistleblowers are not penalized. If a problem is confirmed, we provide guidance, disciplinary action, and education to those involved. We also report the operation of the whistleblowing service to the Compliance Committee.
Number of Whistleblowing Cases
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| 2019 | 2020 | 2021 | 2022 | 2023 | |
|---|---|---|---|---|---|
| Number of cases | 4 | 1 | 2 | 4 | 1 |
Action against violations
Action to be taken when compliance violations are found (e.g., procedures, or announcements in or outside the company) is stipulated in the Compliance Committee Regulations.
When a violation is found, facts are scrutinized and punishment is determined based on the Rules of Employment and Disciplinary Actions Regulations in light of internal regulations, including the Operational Responsibilities Regulations. Company-wide measures to prevent recurrence are discussed and determined. In FY2023, there were three disciplinary cases, some of which concerned harassment.
Fair trade and anti-corruption
The Sanyo Chemical is a member of the United Nations Global Compact. The Code of Corporate Ethics and the Code of Conduct for Employees stipulate commitment to “fair competition, proper transactions, and responsible procurement.” The Operational Responsibility Regulations of business divisions require the “prevention of unlawful transactions and acts, prohibition of bribery, and confirmation of non-violation of export regulations and laws related to chemical substances in respective countries.” Education is offered to employees through “legal consultants.”
We do not violate antimonopoly laws, antitrust laws, or competition laws of respective countries.
Political donations
We do not make political donations.
Transparency regarding the provision and use of research funds, etc.
In accordance with the "Transparency Guidelines" with medical institutions set forth by the Japan Association of Laboratory Medicine and the Japan Federation of Medical Devices Industries, we have established "Guidelines for Transparency in Relationships with Medical Institutions, etc." and announce the status of implementation every year.
≫ GUIDLINES ON THE RELATIONSHIP WITH MEDICAL INSTITUTIONS (In Japanese Only)
In addition, we have announced the appropriate operation and management system for public research expenses.