Compliance
The Kurita Group is involved with solving many customers’ problems in areas around the world. This is proof of the trust that customers in various countries have placed in the Group, and it entails a heavy responsibility. To ensure that we continue to be highly rated as a company by customers, suppliers, employees, shareholders, and local communities throughout the world, we recognize that it is more important than ever to conduct business fairly at all times in every country where we operate. All Kurita Group officers and employees observe the stance stated in our CSR Policy, “Maintain fair and transparent trade based on free competition. Maintain sound relationships with politics and administration,” and are committed to fulfilling the Group’s responsibilities for the future.
Contribution to Achieving the SDGs
Kurita Group Code of Conduct and Code of Ethics
All Kurita Group officers and employees share fairness, transparency, integrity, safety, and compatibility as Code of Ethics, and the Kurita Group Code of Conduct has been created to set out basic guidelines for judgment and conduct for how all Kurita Group officers and employees should conduct themselves and what conduct is prohibited. The Code has been disclosed on the Company website. The Kurita Group’s basic approach toward compliance is to implement this code of conduct by promoting deeper understanding of the code within the organization, reviewing the compliance guidelines formulated at each division and Group company, and promoting awareness of them throughout the organization.
The Kurita Group Code of Conduct
The Kurita Group has formulated the following various policies to ensure the promotion of fair business practices throughout the entire Group, and they are now being applied in Kurita Group companies.
Kurita Group Anti-Bribery Policy and Group Guideline on Anti-Bribery
The Kurita Group formulated its Anti-Bribery Policy to prevent bribery and promote fair business activities within the Group. This policy defines basic items related to the Group’s bribery prevention systems. Under the policy, the Company and each Group company define items to be complied with as rules and works on the reduction of the risk of the occurrence of bribery. We also developed the Group Guideline on Anti-Bribery in fiscal 2021, which establishes more specific rules on preventing bribery. The policy and guideline stipulate the prohibition of bribery through agents such as deputy or mediator.
The Kurita Group Antitrust Policy and Group Guideline on Antitrust
The Kurita Group has established the Kurita Group Antitrust Policy to ensure that the Group conducts fair transactions and to prevent its officers and employees from violating antitrust laws in countries around the world. The policy sets out basic items regarding observing local antitrust laws and antimonopoly laws, and associated regulations in different countries and regions. In addition, we formulated the Group Guideline on Antitrust in fiscal 2021 to establish rules based on the respective business characteristics of the Company and Kurita Group companies.
The Kurita Group Antitrust Policy
These policies have been translated into 16 languages so that all Kurita Group officers and employees throughout the world can understand them.
Promotion System (FY2023)
The Kurita Group has established the E&S Committee and the Group E&S Committee as organizations to oversee compliance activities. Both committees are chaired by a Managing Director of the Company, and the Group E&S Committee’s members are representatives of Group companies. The committees are tasked with deciding polices and key measures related to compliance activities, which are conveyed to all employees through subcommittees in each headquarters division and Group company. The E&S Committee also manages the activities and reports the activity results once a year to the Company’s Board of Directors, which evaluates the activity results.
Targets and Achievements
The Kurita Group’s target for the theme in fiscal 2023 and its achievements are as shown below.
| Target for FY2023 | Achievement in FY2023 | |
|---|---|---|
| Rate of participation in compliance-related training | 100% | 100% |
- * In fiscal 2023, we conducted antitrust law compliance training for executives and employees whose work may involve antitrust law considerations for overseas Group companies.
Main Initiatives
Preventing Problems from Occurring
The Kurita Group has established targets and measures to be taken for improvement of the risk of legal or regulatory infringements, and is working to prevent compliance-related problems from occurring. Specifically, we created a “Non-Compliance Risk Map” consisting of a list of 60 items and tailored to the business characteristics of each organization and company. We have identified key themes to be addressed by conducting risk assessments at each organization and company based on the results of a Compliance Behavior Survey from the previous fiscal year. Based on these findings, we work to make improvements by formulating an improvement plan for each fiscal year.
Compliance Behavior Survey
The Kurita Group conducts the Compliance Behavior Survey for Kurita Group employees and dispatch staff each year in order to clarify the impact of compliance activities and any problems, and to identify latent legal and regulatory infringement risks to help reduce risks going forward. The survey results were reported back to the personnel in charge of compliance in each organization and Group company.
Status of Compliance Behavior Survey Implementation
| FY2021 | FY2022 | FY2023 | |
|---|---|---|---|
| Number of people surveyed | 7,503 | 7,531 | 7,630 |
| Number of respondents | 7,413 | 7,386 | 7,512 |
| Response rate (%) | 98.8 | 98.1 | 98.5 |
Whistleblowing and Consultation Desk
The Kurita Group seeks to enable employees to work in the Group with peace of mind.
To this end, we have established the Kurita Group Code of Conduct, as well as
Whistleblowing and Consultation Desk within and outside group where people can
report or consult if they observe behavior that breaks laws, internal company rules.
These desks are available 24/7 for officers, employees, dispatched workers, and
employees of business partners (hereafter referred to as "whistleblowers")
. These desks and how to use it are posted on the company intranet for Group
employees, and distributed pamphlets to business partners to inform them on a
regular basis and provide regular training.
In Japan, whistleblowers can use the hotline anonymously, and the Kurita Group
operates a system to protect whistleblowers from disadvantageous treatment such as
retaliation. In addition, the operating status of the whistleblowing system is
reported once a year to the Board of Directors by Executive general manager of the
Corporate Planning and Management Office of the Company.
Through these systems and mechanisms, the Kurita Group strives to protect those who
consult and report and to detect misconduct at an early stage.
Status of Consultation Desk Usage (Cases)
| FY2021 | FY2022 | FY2023 | |
|---|---|---|---|
| Japan | 21 | 30 | 23 |
| Overseas | 2 | 1 | 3 |
| Total | 23 | 31 | 26 |
Compliance Training for Management
The Company conducts ongoing compliance training for its management team and those of its domestic Group companies. In fiscal 2023, the theme of the training was “Respect for Human Rights: A Corporate Responsibility Expected by the International Community.” A total of 32 people participated.
Antitrust Law Training
The Kurita Group conducts antitrust law training to ensure that officers and employees of the Kurita Group conduct fair transactions based on the Kurita Group Antitrust Policy and to prevent any violation of antitrust laws worldwide. In fiscal 2023, we conducted training for officers and employees of overseas Group companies.
CSR Requirements for Suppliers
The Kurita Group considers it vital to obtain cooperation from suppliers to conduct
fair business across the entire supply chain. We have established the Kurita Group
CSR Procurement Guidelines, and we have asked suppliers to observe laws and social
norms, such as conducting fair business and prohibiting corruption and bribery, and
to provide appropriate information. In particular, we ask major suppliers to conduct
a self-evaluation based on the guideline and to implement improvement measures.
In
addition, since fiscal 2022, we have been using the platform* of EcoVadis
for the purpose of expanding evaluation items, enhancing the reliability of
evaluation results, and reducing the burden on suppliers. As of March 2023, 123
suppliers in Japan and overseas (accounting for 28% of total order amount in fiscal
2021) were registered on the platform.
- * A platform for rating the sustainable procurement capabilities of suppliers from a CSR perspective. The content and number of questions are customized according to industry, company size, and country or region.