Conduct Fair Business Activities
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 directors 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.
Promoting Compliance Activities
Basic Approach toward Compliance
All Kurita Group directors and employees share fairness, transparency, integrity, safety, and compatibility as five core values,and the Kurita Group Code of Conduct has been created to set out basic guidelines for judgment and conduct for how all Kurita Group directors and employees should conduct themselves and what conduct is prohibited. The Code has been translated into 18 languages so that all Kurita Group directors and employees throughout the world can understand it, and it is also 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.
Formulation of Policies
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’s Anti-Bribery Policy
The Kurita Group formulated its Anti-Bribery Policy in order 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 this policy, the Company and each Group company defines items to be complied with as rules and works on the reduction of the risk of the occurrence of bribery.
Kurita Group Antitrust Policy
The Kurita Group has established the Kurita Group Antitrust Policy to ensure that the Group conducts fair and proper transactions and to prevent its directors 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 and so forth in different countries and regions.
In 2006, the Company and its Group companies in Japan withdrew, in principle, from all construction projects ordered by the national government and local public entities. However, the Company made exceptions for facilities that it has delivered for which Group companies continue to perform maintenance and management operations. The Group will continue these projects after each has been approved by the Board of Directors, provided they are confirmed to be free of compliance risk.
These policies has been translated into 16 languages so that all Kurita Group directors and employees throughout the world can understand it.
As an organization for overseeing the Kurita Group’s compliance activities, the Company has established the E&S (Environmental & Social) Committee, which is chaired by a director of the Company, and the Group E&S Committee, which is also chaired by the abovementioned director and whose members are representative directors of 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 and Group company. The E&S Committee manages the activities and reports the activity results once a year to the Company’s Board of Directors, which evaluates the activity results.
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, after creating a “Non-Compliance Risk Map” consisting of 60 items and tailored to the business characteristics of each organization and company, we have identified key themes to be addressed by conducting a risk assessment based on the results of a Compliance Behavior Survey from the previous fiscal year. In fiscal 2018, we established themes such as “preventing leakage of confidential information”, “reducing overtime hours”, and “preventing data tampering”, and took steps to reduce risks by holding workplace discussions, creating manuals, and other means. In particular, risks related to corruption have a great impact on the overall Group, so we take initiatives for reducing such risks intensively at seven overseas Group companies and two domestic Group companies that were judged to have high corruption-related risks.
Compliance Behavior Survey
The Kurita Group conducts the Compliance Behavior Survey 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 risks. In fiscal 2018, the surveys were conducted for employees and dispatch staff at 26 companies in Japan, including the Company, and at 19 companies overseas (6,521 subjects, 6,230 respondents, 96% response rate). The survey results were reported back to the personnel in charge of compliance in each organization and Group company.
Whistle-Blowing 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 consultation desks within each company and outside organizations where people can report or consult if they observe behavior that breaks internal company rules or behavior that they think might be breaking the rules, or if they have business partners who may not be following the rules. These consultation desks are provided not only for Kurita Group employees, but also for dispatch staff sent to work in the Kurita Group and personnel at our customers and so forth. They are designed in an effort to protect persons who consult or make reports and to achieve early detection of dishonest practices. Moreover, we also operate the Kurita Global Helpline, which allows the employees of overseas Group companies to make reports to a consultation desk. In fiscal 2018, the consultation desk in Japan was used 26 times, and the consultation desk overseas was used once, for a total of 27 times.
Compliance Training for Management
The Company conducts ongoing compliance training for its management team and those of its domestic Group companies.In fiscal 2018, a lawyer specializing in competition law (antitrust law) was invited to lecture in a training program about legal and regulatory trends in various countries amid the advance of globalization and increasing risks to companies, mainly focusing on cartels and bribery. The training was attended by 39 people from the Company and 38 people from domestic Group companies for a total of 77 people.
Anti-Bribery and Anti-Corruption Training
The Kurita Group provided anti-bribery and anti-corruption e-learning training for all of its directors and employees in fiscal 2019. The training is designed to deepen understanding about points that should be observed by all directors and employees in accordance with the Kurita Group Anti-Bribery Policy, as well as to promote fair business activities. It was held at the Company and domestic Group companies, with a 100% attendance rate. Training for overseas Group companies is to be implemented in fiscal 2020.
As shown in the table below, during fiscal 2018, there were no major legal or regulatory infringements within the Kurita Group, no cases of employee discipline or dismissal related to legal or regulatory infringements, and no expenses incurred for payment of fines (Please see “Governance” under “CSR Data.”)
|Cases involving violations or sanctions related to bribery||0|
|Legal actions for anti-competitive behavior||0|
|Legal actions for anti-trust practices||0|
|Legal actions for monopoly practices||0|
|Non-compliance with environmental laws and regulations||0|
|Incidents of non-compliance concerning product and service information and labeling||0|
|Incidents of non-compliance concerning marketing communications||0|
|Substantiated complaints concerning breaches of customer privacy and losses of customer data||0|
|Non-compliance with laws and regulations in the social and economic area||0|
|Other incidents of non-compliance||0|
Targets for Fiscal 2023
The Kurita Group has set a target for this theme to be achieved by 2023, as shown on the right.
Rate of participation in compliance-related training among directors and employees: