The Company has established the Compliance Committee, which is chaired by the representative director, and the Group Compliance Committee, which is also chaired by abovementioned representative director and whose members are the representatives of domestic Group companies. In these committees, the Group sets out policies and important measures for compliance activities, and conveys them to all employees through subcommittees at each headquarters division, business division, and Group company.
The Kurita Group does not see compliance activities simply as the observance of laws but rather as the practice of conduct in accordance with social ethics. We have thus established the Core Values and the Kurita Group Code of Conduct and we fully enforce the practice of conduct based on compliance with laws, regulations and social ethics in our daily business activities.
Framework for Promotion
Scene from the Compliance Committee
Compliance Behavior Surveys are conducted once a year on the employees of the Company and the domestic Group companies. Additionally, in 2015 Compliance Awareness Surveys were also being conducted on the employees of the overseas Group companies. The Company, through these surveys, monitors the level of compliance awareness and the implementation of compliance behavior among employees. Issues that become apparent through analysis of survey results are reflected in compliance activity plans, and utilized in initiatives to solve compliance issues.
Initiatives to Prevent Bid-Rigging and Cartels
In 2006, the Kurita Group withdrew, in principle, from all construction projects ordered by the national government and local public entities to ensure no recurrence of violations of the Antimonopoly Act (cartels). Exceptions to this principle are limited to projects involving facilities delivered by the Company subject to ongoing maintenance and management work by Group companies, which are executed by obtaining the approval of the Board of Directors on a caseby-case basis. We also forbid participation and membership of trade associations in order to exclude all dealings with associates.
Initiatives to Ensure Observance of the Subcontract Act
Since 2008, the Company has been conducting Surveys on Transactions with Kurita Water Industries Ltd. once a year on suppliers who fall under the category of subcontractors as provided in the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors (Subcontract Act). The Company is promoting fairer transactions and building a relationship of mutual trust and cooperation by continuously improving its transactions and its methods of transactions based on the opinions and suggestions voiced by its suppliers.
Whistle-Blower Protection Rules
The Group and its domestic Group companies have established the Public Interest Whistle-Blower Protection Rules and maintain consultation desks both within the Group and at outside organizations, in an effort to protect persons who consult or make reports and to achieve early detection of dishonest practices. Starting from April 2016, the Kurita Global Helpline, which allows employees of overseas Group companies to make reports to the consultation desk, has also commenced operation.
Prohibition of the Provision and Acquisition of Profits
The Kurita Group, in accordance with the Code of Ethical Conduct and the Compliance Guidelines, prohibits illegal gifts or payment, and giving and receiving unjust profits either in a monetary or non-monetary form.