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
In order to comprehensively and exhaustively ascertain the risks facing the Group and respond appropriately, the Compliance Committee was dissolved and reorganized into the Risk Management Committee for better risk management in FY2025. In addition to the role of promoting company-wide compliance activities, which was previously carried out by the Compliance Committee, the Risk Management Committee will now be responsible for formulating basic policies, providing guidance, and overseeing company-wide risk management and internal control. The Director in charge of corporate ethics, which we have appointed to oversee efforts to promote company-wide compliance, works to ensure that compliance is widely known and thoroughly implemented throughout the Company.
We have also set up the Internal Audit Office under the direct control of the President, so as to strengthen our internal auditing function.
In FY2024, the Compliance Committee discussed the curriculum that employees learn in company-wide Corporate Ethics Study Sessions, while also reviewing compliance systems at overseas Group companies.
Compliance System Diagram
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 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.
We take seriously the fact that four cases of harassment occurred within the Group in FY2022, and have held study sessions on harassment since FY2023. In FY2024, 1,450 people in the Group (approx. 95% of all employees) watched a short educational video on the topic of harassment and then participated in a group discussion. After the sessions, a questionnaire survey was conducted to evaluate the Group’s overall compliance activities, with a view to reflecting the results in educational activities in the following fiscal years.
Legal Training Program
Employees of the Legal Affairs Dept. offer “legal training” for Group employees in Japan. They give lectures on various themes. Personnel in charge of the Legal Affairs Dept. are designated as contact people for respective organizations (such as business divisions, and subsidiaries and affiliates). Such arrangements make it easy to seek legal advice.
Training Content for FY2024
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| Contents | Target people |
|---|---|
| Basic Knowledge about Contract | All employees |
| Insider Transaction Regulations | New employees, mid-career employees |
| Export Trade Control Order | Sales and research staff |
| Subcontract Act | All employees |
| Bribery and corruption prevention | All employees |
| Trade secrets and the Unfair Competition Prevention Act | All employees |
| Quality fraud prevention | All employees |
| Supplier bankruptcy and debt collection | Sales staff |
| Fundamentals of basic transaction agreements | 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 Senior Manager of the Internal Audit Office, 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.
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 FY2024, the number of hotlines used was four in total, and it concerned harassment. We investigate facts with the utmost care to ensure that whistleblowers do not incur any detriment. If a problem is confirmed, we provide guidance, disciplinary action, and education to those involved. We also report on the operation of the whistleblowing service to the Risk Management Committee.
Number of Whistleblowing Cases
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| FY2020 | FY2021 | FY2022 | FY2023 | FY2024 | |
|---|---|---|---|---|---|
| Number of reports (cases) | 1 | 2 | 4 | 1 | 4 |
Action Against Violations
Action to be taken when compliance violations are found (e.g., countermeasures, or announcements in or outside the Company) is stipulated in the Risk Management 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 referring to internal regulations, such as the Operational Responsibility Regulations. Company-wide measures to prevent recurrence are discussed and determined. In FY2024, there was one disciplinary case.
Fair Transaction 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 training.”
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 spending, 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 on the Relationship with Medical Institutions, etc." and announce the status of implementation every year.
≫ GUIDELINES ON THE RELATIONSHIP WITH MEDICAL INSTITUTIONS (Japanese Only)
We have announced the appropriate operation and management system for public research spending.