1.Objectives of this Policy
This policy aims to prevent acts that violate or may violate the Antitrust Laws or acts that may be misunderstood as violation of the Antitrust Laws and to promote fair and free competition by setting forth the following matters:
- ［1］Basic matters related to compliance with the Antitrust Laws, competition laws , antimonopoly laws and other similar laws and regulations, etc. of each country or region (hereinafter, the "Antitrust Laws") by Kurita Water Industries Ltd. (hereinafter, "KWI") and its consolidated subsidiaries (hereinafter, "Group Companies;" KWI and Group Companies are hereinafter collectively referred to as the "Kurita Group"); and
- ［2］Matters to be observed by the officers and employees of the Kurita Group (the directors, members of the audit & supervisory board, executive officers, corporate officers, personnel equivalent to them of the Kurita Group) are hereinafter referred to as the "Officers, etc." the employees of the Kurita Group are hereinafter referred to as the "Employees" and the officers and employees of the Kurita Group are hereinafter collectively referred to as the "Officers, etc. / Employees" ).
2.General provisions
- （1）In accordance with the Kurita Group Antitrust Policy (hereinafter, this "Policy"), the Kurita Group shall prohibit any act of the Officers, etc. / Employees that violates the Antitrust Laws, construct necessary structures to comply with the Antitrust Laws and establish regulations setting forth the rules and other matters for compliance (hereinafter, the "Regulations for Compliance with the Antitrust Laws").
- （2）The Regulations for Compliance with Antitrust Laws shall be in compliance with the provisions of this Policy on violating acts as well as applicable laws and regulations, etc. of each country or region where each company of the Kurita Group operates its business (hereinafter collectively, the "Local Laws and Regulations").
- （3）The Officers, etc. / Employees shall observe this Policy and shall not violate the Antitrust Laws. In addition, they shall strive to prevent any violation of the Antitrust Laws.
- （4）The Representative Director of KWI or the Chief Compliance Officer appointed by the Representative Director shall oversee the activities of the Kurita Group intended for compliance with the Antitrust Laws.
- （5）Any Employee who has any question as to the Antitrust Laws and this Policy in performing his/her duties shall consult with the Compliance Officer stipulated in the Regulations for Compliance with Antitrust Laws (hereinafter, the "Compliance Officer") or the Ethics & Integrity Department of the Sustainability Division of KWI for appropriate instructions.
3.Rules on acts that violate Antitrust Laws and contact with competitors
None of the Officers, etc. / Employees shall engage in any act that falls under any of the items described below. Examples of the main acts and the rules on contact with competitors are as shown in the Group Antitrust Guidelines.
- ［1］Acts that restrict competition with competitors
- ［2］Acts that restrict competition with distributors (e.g., stores and retailers) or suppliers
- ［3］Any act that abuses market-dominant positions; or
- ［4］Any other act that is regulated by the Local Laws and Regulations.
4.Whistle-blowing
- （1）Any Employee who himself/herself has committed any violation of the Antitrust Laws or becomes aware of any violation committed by another person shall consult with and notify the Compliance Manager or the whistle-blowing office of each Group Company or KWI.
- （2）Group Companies shall immediately report to KWI if they become aware of the fact that any of the Officers, etc. / Employees has violated the Antitrust Laws or the fact that any of the Officers, etc. / Employees has been asked to commit any act that violates the Antitrust Laws.
5.Response to on-site inspection by authorities in charge of the Antitrust Laws
If any authority in charge of the Antitrust Laws conducts an on-site inspection of the Kurita Group, the Officers, etc. / Employees involved in the on-site inspection shall fully cooperate with the authority in charge of the Antitrust Laws in the inspection.
Actions to be taken by and prohibitions applicable to the Officers, etc. / Employees involved in onsite inspections shall be separately stipulated.
6.Education and training
The Kurita Group shall develop and implement systems for providing compliance education and training concerning the observance of the Antitrust Laws on a regular basis.
7.Periodic review and improvement of systems for compliance with the Antitrust Laws
- （1）In order to comply with the Antitrust Laws, the Kurita Group shall periodically confirm the situation of compliance with the Antitrust Laws through such means as self-inspection, inspections by the legal department or audits by the internal audit department and make improvements as necessary if any problem is identified.
- （2）The Officers, etc. / Employees shall cooperate with the Kurita Group in its audits relating to the Antitrust Laws or inspections relating to violation of the Antitrust Laws.
8.Department in charge
The department responsible for enforcing this Policy shall be the Ethics & Integrity Department of the Sustainability Division of KWI.
9.Changes, etc. to this policy
KWI shall amend or abolish this Policy based on the Management Regulations for Policies and Regulations of KWI in light of trends in laws and regulations related to this Policy and the operation of this Policy within the Kurita Group.
Supplemental provision
- （1）This Policy shall be established and enforced on November 1, 2017.
- （5）This Policy shall be revised and take effect on June 29, 2023.