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.”
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 FY2022, 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 Auditing Division under the direct control of the President, so as to strengthen our internal auditing function.
Compliance promotion structure
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The Advice on Compliance and the Code of Conduct for Employees establishes specific criteria on daily behavior for employees.
Internal auditing
The Auditing Division conducts internal auditing. It objectively inspects and evaluates the business management and operation systems and the status of business execution in terms of legitimacy, effectiveness, and efficiency. Based on the results, it makes proposals for improvement or corrective recommendations, in order to facilitate the Company's sound management and sustainable development.
Education activities
Corporate ethics study sessions
Every year, the Sanyo Chemical Group holds sessions to study corporate ethics across all departments with the objective of preventing the occurrence of corporate misconduct. In recent years, these sessions have placed particular focus on the kind of corporate culture that may form the background to corporate misconduct. Participants learn that corporate culture reform leads to improved compliance by watching videos (short dramas). In FY2022, participants watched a video on the theme of “a workplace where negative information is reported” and held group discussions. In total, 1,885 participants joined the sessions. After the sessions, a questionnaire survey was conducted to evaluate the overall compliance activities of the Group and reflect the results on the education activities in the following fiscal years.
Legal consultant program
Employees of the Legal Affairs Department offer legal consultants for Group employees in Japan. They give lectures on various themes. Personnel in charge of the Legal Affairs Department are designated as contact persons for respective organizations (including business divisions and subsidiaries and affiliates). Employees of the Legal Affairs Department 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 FY2022
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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 |
| Joint development and joint application | Research Young and mid-career employees |
| Subcontract Act | Employees working with subcontractors |
| Trade secrets | Sales and research staff |
Internal whistleblowing system
If an employee becomes aware of a compliance problem, the employee should basically discuss it with his/her supervisor and/or the personnel concerned. However, if the problem cannot be resolved through such discussions, the whistleblowing contact points (compliance hotline) that conform with the Whistleblower Protection Act are set up both inside the Company and outside in accordance with the internal Whistleblowing Regulation. The General Manager of the Auditing Division, who is a member of the Compliance Committee Secretariat, serves as the internal contact point for whistleblowing. The corporate lawyer is available for the contact point outside the Company. We operate the regulation requiring that the whistleblowers’ confidentiality be carefully protected to prevent the identification of whistleblowers.
In FY2022, four reports in total were submitted through the compliance hotline. All of these reports were related to harassment. The facts were investigated with utmost care so that whistleblowers would not be disadvantaged. For problems identified, guidance was offered and disciplinary action was taken for target individuals, and education was offered to correct the situation.
Previously, the Sexual Harassment, Maternity Harassment, and LGBT Contact Points dedicated to harassment problems were in place separately from the whistleblowing contact points. In April 2023, a consultation desk for harassment problems was newly established outside the Company. A mechanism will be created so that the whistleblowing contact points and the consultation desk are readily accessible to whistleblowers (employees seeking consultation services). The status of operation of the whistleblowing contact points is reported to the Compliance Committee.
Number of whistleblowing cases
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| FY | 2018 | 2019 | 2020 | 2021 | 2022 |
|---|---|---|---|---|---|
| Number of cases | 1 | 4 | 1 | 2 | 4 |
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 FY2022, there were four cases subject to disciplinary actions. Specifically, three cases were related to harassment, and one case was related to violation of company policy.
Fair trade and anti-corruption
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 “egal 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.
Click here for the Guidelines for Transparency in Relationships with Medical Institutions and public information(In Japanese Only).
In addition, we have announced the appropriate operation and management system for public research expenses.
Click here for Management System for Public Research Funds(In Japanese Only).