In line with our basic philosophy, we declare: “By honoring the spirit of the law and ethics, the company aims to be a corporate citizen that coexists with nature and the local community.” We conduct our compliance activities aiming not only to ensure compliance with the laws and regulations, but also to meet social expectations.

Promotion system and structure

Specific activities

• Compliance Highlight Month activities

   　In the ‘‘Compliance Highlight Month activities’’ implemented in October every year, we aim to maintain and raise awareness regarding compliance. Besides opportunities to debate compliance matters in workplaces, things like messages when starting up PCs, company newsletters, officers’ lectures, DVD screenings and so on are also included in the activities.

• Group compliance

   　With the compliance management division and divisions in charge of legal compliance as our core, our domestic and overseas subsidiaries have been jointly organizing systems and carrying out awareness activities in accordance with the status and circumstances of each company.

• Initiatives to prevent bribery and corruption

   　We have established the ‘‘Anti-Bribery Compliance Manual’’ as a guideline for promoting business activities based on fair competition. We clearly prohibit bribery in the ‘‘Employee Code of Conduct,’’ Tokai Rika-ism, and ‘‘CSR guidelines,’’ and are disseminating these internally. We have also established a mechanism to prevent bribery throughout our Group. Specifically, we raise awareness through pre-assignment training, receive regular reports from each business entity, and respond to any problems that arise. Furthermore, we support each business entity in establishing guidelines, systems, and procedures related to bribery prevention.
  
  The outline of the ‘‘Anti-Bribery Compliance Manual’’ is as follows:

  •  　1. Establishment of anti-bribery guidelines
     Items: Prohibition of offer and acceptance of bribes, prohibition of accounting fraud, and cooperation with investigation
  •  　2. Stipulate the implementation of awareness-raising and education on bribery prevention
  •  　3. Stipulate where to report/consult regarding bribery and accounting fraud
  •  　4. Stipulate guidance and support for subsidiaries and affiliated companies (group companies) regarding bribery prevention

• Prevention of anti-competitive behavior

  　We have established the ‘‘Antimonopoly Act Compliance Manual’’ and are working to prevent anti-competitive behavior. We clearly prohibit anti-competitive behavior in the ‘‘Employee Code of Conduct’’ and Tokai Rika-ism, and are disseminating these internally. In addition, we conduct ongoing awareness-raising activities by conducting training specializing in competition law every January.
  　Furthermore, as part of our group-wide effort to prevent competition law violations, we have established a system to receive reports from each business entity on a regular basis and respond to any problems that arise.

• Consultation reporting

  　In order to detect and solve internal problems at an early stage, we have established a consultation and whistleblowing service inside and outside the company. Inside the company, a consultation and whistleblowing service has been established at the Head Office, in each plant and at labor unions, in order to collect knowledge of problems from a broad range at an early stage as far as possible. We have also named the service ‘‘Nandemo Soudan Madoguchi’’ (‘‘Consult us on Anything Service’’), so as to make the service more easily accessible. Furthermore, we have established a whistleblowing service in an external law firm as a ‘‘compliance call’’ service so that employees who feel apprehensive about using the internal consultation will feel more at ease. Confidentiality will be strictly maintained in order to assure that the consulter will not be specified. As shown in the following graph, there are a certain number of consultations every year, and the service is bringing early resolutions to problems.