Compliance
Compliance
Compliance Basic Policy
By achieving thoroughgoing commitment to "compliance with domestic and international laws, our articles of incorporation, internal regulations and corporate ethics" (Compliance) and through open and fair corporate activities, we aim to be a company that international society relies on.
- Standards for Employee Behavior
- Structure for Promoting Compliance Program
- Bolstering Compliance Activities
Standards for Employee Behavior
The IBIDEN Group has established the "Standards for Employee Behavior" based on the Compliance Basic Policy and the IBIDEN Group Charter of Behavior as standards for each member of the Company, including officers and employees, to practice compliance sincerely.
The contents of the Standards for Employee Behavior are reviewed and revised as required every year based on compliance with the laws and regulations of each country and meeting the expectations and requests of stakeholders in global business development. Furthermore, we reflect revisions to the standards in in-house compliance promotion structures and education to raise the compliance level of the Company and each of its members.
Structure for Promoting Compliance Program
Compliance promotion activities are conducted by the Division Manager in charge of Compliance Promotion appointed by the Executive Officer in charge, and reported to the Compliance Company-Wide Promotional Committee (Secretariat: Compliance Promotion Division ; frequency of holding the committee meeting: At least once a year) chaired by the President & CEO.
The committee reports and reviews the group-wide compliance promotion, supervision, and activities. Compliance-related policies and plans decided by the committee are communicated to each plant and domestic and overseas group companies, which in turn rolls out individual actions in accordance with them. All group companies both in Japan and abroad have set up their own compliance organizations mandated to formulate and conduct individual actions.
The Executive Officer in charge of compliance delivers an annual report to the Board of Directors regarding the number of the consultation cases through the whistleblowing system and the analysis results and also regarding the state of the compliance activities including those against legal violation, prevention of all forms of corruption, and human rights violation. The Executive Officer receives confirmation and supervision of the effectiveness of an activity program as a whole that include the Standards for Employee Behavior by the Board of Directors.
Whistleblowing System
In addition to the formal channel of reporting, the Group has established a compliance consultation service to facilitate reporting when an officer or employee*1 discovers a violation of compliance, including legal violation, unlawful actions and human rights violation. The Company's consultation counter includes a counter through which the whistleblower can report nominally to the person in charge of the consultation service, and a counter through which the whistleblower can report anonymously to an outside expert. Also, domestic and overseas companies of IBIDEN Group have respectively established and operated consultation counters unique to each company.
The consultation counters have been operated in accordance with the Whistleblower Protection Act with due consideration for the protection of rights of whistleblowers, such as securing the anonymity of persons who seek consultation, protecting their privacy, and guaranteeing that they will not be treated disadvantageously. Furthermore, to deepen understanding and enhance the reliability of the system, we have established a support channel that averts conflict of interest at the time of reporting.
To create an environment where employees feel comfortable consulting, we endeavor to make the service known to everyone by distributing cards which describe how to use the service, putting up posters, and training for officers and employees.
Should an incident related to compliance occur, the Compliance Committee chaired by the Executive Officer in charge of compliance promotion is called and discussions take place on appropriate actions to address the situation as well as preventative measures for future incidents. Serious incidents in particular are reported to the Board of Directors.
In FY2022, our company and major domestic Group companies receive 21 cases of consultation*2
*1：Compliance consultation service is available to all those working at on-site workplaces.
*2：The number includes consultations which overlap several categories and consultations of matters which cannot be confirmed as facts.
Bolstering Compliance Activities
Compliance Education
When promoting compliance activities, it is crucial that employee awareness is continuously maintained at a high level. The Company has established an environment enabling all those working at on-site workplaces (including part-time workers and contract workers) to systematically receive education and training immediately after their employment regarding the Standards for Employee Behavior, which sets forth the compliance standards to be followed by officers and employees. We also annually provide education and training designed to update trainees' knowledge. In addition to education based on the Standards for Employee Behavior, we are promoting special education programs, including ones focused on various laws and regulations and corporate taxation.
At overseas bases, which employ many immigrant workers, training is provided on educational training such as the Standards for Employee Behavior in workers'native language so that they can fully understand the contents of the training. To deepen the understanding of the details of the Standards for Employee Behavior, we have issued Case Examples for Enlightenment (Case Book), which introduces cases of violation of the Standards and points to remember for compliance, reading them through the workplace to raise employees 'awareness of compliance.
Efforts for Fraud Prevention including Anti-bribery
The Group upholds the IBIDEN Group Charter of Behavior to make efforts to prevent every form of corruption. In the Standards for Employee Behavior also, we demand ethical behavior education for all those working at on-site workplace (including part-time workers and contract workers), and strictly prohibit unlawful actions and acts of conflict of interest including bribery. The IBIDEN Group's businesses do not have many direct dealings with government or municipal offices, so the overall risk of being charged with fraud is not high according to the results of assessments of corruption risk at each site. However, to avoid misconduct, we have appropriately developed a system for ensuring a certain prevention of corruption in line with the current conditions of each site, including measures such as stricter authorization when paying social expenses, the establishment of Gift-giving and -receiving Guidelines, and the development of a Whistleblowing System. In the IBIDEN Group Supply Chain CSR Guidelines, which outline the specific responses to be taken by our suppliers in Japan and abroad and with which we ask suppliers to pledge compliance at the start of business, we request suppliers to take action to prevent corruption based on our procurement guidelines that place top priority on fairness and equity.
In support of the purport of the scheme of the "Declaration of Partnership Building," which was introduced by the Cabinet Office, the Ministry of Economy, Trade and Industry, the Small and Medium Enterprise Agency, etc. with the aim of achieving co-existence and co-prosperity in the supply chain and mutual enhancement of added value through new partnerships, we announced our declaration in March 2022 under the name of our president. To build a future-oriented strategic partnership with our suppliers based on compliance with preferable business customs between parent businesses and subcontractors, we are making efforts to further strengthen relationships beyond the legal restrictions of the Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors.
Moreover, we conduct an internal audit regarding our ethical standards, including those intended to prevent misconduct, for all business units, and make efforts to discover and correct fraud at an early phase for example by using data when conducing such an internal audit. As for outside audits, we voluntarily receive the Validated Assessment Program (VAP), including on-site inspection regarding unlawful actions and other ethical problems, document inspection, and interviews with employees, from a third-party audit organization certified by the industrial institute RBA.
In fiscal 2022, there were no violations of our employees' code of conduct that would have affected our business activities, no fines or settlements related to fraud, and no disciplinary actions confirmed.
Self-Check of Activities and Awareness Survey
We conduct a self-check on the status of compliance with the Standards for Employee Behavior and a survey on compliance awareness each year, covering all employees including those of domestic Group companies.
In the self-check, all employees, including those holding managerial posts, diagnose the state of compliance with items of the Standards for Employee Behavior, and compliance-related challenges at each Group company or plant are clarified by summarizing the results of the diagnosis. Any problem identified in this process is addressed through remedial activities at Group companies and plants in the following fiscal year. We link little understood topics with educational programs. For instance, case studies illustrating compliance-related issues that many test-takers failed to answer correctly are published to increase their understanding. In the awareness survey, we evaluate and analyze the degree of employee satisfaction with their workplace and superiors and compliance violation risk items from various aspects.
System and Achievement of Legal Compliance
Compliance with laws and regulations is a fundamental requirement for corporate compliance activities, and the latest information on laws and regulations is required all the time. At the Company, based on the Compliance Regulations, divisions in charge such as the Legal sections, Human resource sections and Environment & Safety sections, list laws and regulations that affect the Company and monitor the status of their revision or abolition. They also notifies related divisions of each law and regulation of any revision or promulgation and, when any action is required, checks the results of such action.
In particular, we designate laws and regulations that have a significant impact on the IBIDEN Group as the "most important laws and regulations". We exercise management and thoroughly implement measures to prevent legal violation by clarification of compliance rules, training to keep everyone informed, regular review of the status of compliance and audits.
IBIDEN Tax Policy
Setting its basic principle as business activities that comply with laws and regulations, our company shall contribute to society through proper payment of taxes, and shall strive to maximize our corporate value by optimizing tax costs. In line with this notion, we formulated the IBIDEN Tax Policy, which shall apply to the IBIDEN Group.
| IBIDEN Tax Policy (PDF/127KB) |