Compliance
We have established the Sumitomo Seika Group Charter for Business Conduct as a code of conduct for every employee and board member of the entire Group conducts corporate activities based on this code and strives to comply with related laws, regulations, and ethical standards.
Sumitomo Seika Group Charter for Business Conduct
The Sumitomo Seika Group (“the Group”) and every board member, executive officer and employee of every company of the Group must, in conformity with the following principles, act with the highest ethical standards and in a socially prudent manner, respect human rights and abide by all relevant laws, regulations and other rules.
- We contribute to society by developing and delivering high-quality and safe products and services.
- We respect the intellectual properties and trade secrets of others and protect personal information and customer information thoroughly.
- We never offer or receive economic benefits with the aim of gaining unjustified benefits or become involved in conduct that can lead to corruption involving a government official, whether domestic or foreign, nor engage in conduct that can impede fair and free competition.
- We respect employees’ freedom of association and fundamental labor rights, including the right to collective bargaining, as well as their individuality, provide a safe, clean and harassment-free working environment and fair and non-discriminatory working conditions, and cultivate a workplace climate in which employees can gain a sense of fulfillment from their work.
- We supply products that care for environmental stewardship, ensure stringent management of chemical substances, and take all possible measures to prevent accidents and ensure safety.
- We respect human rights of every person who is engaged in the business of the Group and never carry out any act in violation of human rights, such as discriminatory practices, forced labor and child labor.
- We disclose company information as appropriate and fulfill accountability to all stakeholders of respective companies of the Group, such as shareholders, suppliers, customers, employees, and local communities.
- We not only abide by the laws, regulations and other rules of the countries in which we operate, but also respect their local cultures and customs, and contribute to the social and economic development of the countries as our business operations expand geographically on a global scale.
- We stand firm against anti-social forces and groups and have no relationships whatsoever with them.
- We require every person, in addition to those within the Group, who is engaged in the business of the Group as well as a corporation and an organization to which he or she belongs to conduct business in conformity with the letter and spirit of this Charter, thereby working together to build a responsible supply chain across the Group.
Preventing Harassment
Harassment in the workplace is a socially unacceptable act that unfairly undermines workers' dignity as individuals. It is also a problem that hinders the effective exercise of a worker's abilities, interferes with workplace order and the performance of work for their company, and affects its social reputation.
Based on the Sumitomo Seika Group Charter for Business Conduct, the Company respects the rights and individuality of its employees, provides a safe and clean working environment and fair working conditions, and aims to create an organizational culture in which employees can work with a sense of fulfillment. Our employment regulations also clearly prohibit sexual harassment, power harassment, and other forms of harassment that may worsen the workplace environment, and we strive to ensure the prevention of such harassment.
In addition, we have established a Harassment Response Policy and Harassment Prevention Regulations for the purpose of preventing various types of harassment and promptly responding to such harassment if it occurs. We have also set up internal and external consultation desks so that employees and others can consult with us at any time without anxiety.
Furthermore, in addition to raising awareness among all employees through regular harassment prevention training, we are working to raise the level of our harassment prevention system by conducting specialized training for the counselors who serve as the contact points for consultation.
Ensuring Compliance
To ensure compliance, it is important to establish a system (compliance system) to continuously check, correct, and review the status of our business operations, and to operate this system appropriately.
From this perspective, we have established and are operating the following systems.
- Formulate rules and compliance measures to ensure compliance
- Firmly establish compliance rules through employee education and compliance measures
- Accept reports of rule violations through the internal reporting system
- Conduct internal audits to ensure conformity with rules for business execution
- The Internal Control Committee checks the status of the above ⑴ to ⑷ and gives instructions for improvement (i.e., the PDCA (Plan-Do-Check-Action) cycle).
The following are examples of compliance training conducted in FY2021.
- Comprehensive compliance training for new employees
- Training on rules for gifts and entertainment
- Training on antitrust law
- Training on export control of controlled cargo, etc.
- Training on information management
Internal Reporting System
Outline of the System
The Group has established internal and external reporting channels for those inside and outside the Group, including officers, employees, retirees, and business partners of the Company and the Group, to directly report compliance violations or potential compliance violations. Through this system, we are working to detect and prevent compliance violations at an early stage. Internal reporting can be done through our website.
The Company's website and reporting contact points are as follows:
Website
The details of each reporting destination are as follows:
〈Company Help Desk〉
The Sumitomo Building 4-5-33 Kitahama, Chuo-ku, Osaka 541-0041, Japan
Sumitomo Seika Chemicals Co., Ltd.
Legal Department
Internal Control Committee
〈External reporting destination〉
Kitahama MID Bldg. 11F, 1-6-7 Doshomachi, Chuo-ku, Osaka 541-0045, Japan
FrontRow Law Office
Attorney at Law Mr. HIGENO Jumpei
- The external contact above is responsible only for ① receiving consultations and reports and ② reporting to the Company.
After receiving a report, the Internal Control Committee Secretariat will take action. - Anonymous reporting is also possible.
- The name and affiliation of the person reporting the matter to the external contact above may be kept confidential when the external contact reports the content of the report to the Company. However, depending on the nature of the case, it may not be possible to keep the information confidential.
Protecting Whistleblowers
Principle Handling with Regard to Confidentiality of Whistleblower's Name
In addition to the name of the whistleblower, the content of the report and other information that may lead to the identification of the whistleblower shall be kept confidential during the investigation of the matter reported, unless the whistleblower requests disclosure of such information.
Thorough Prohibition of Disadvantageous Treatment of Whistleblowers
To ensure that whistleblowers are not treated disadvantageously as a result of their reporting, we have established company rules that prohibit disadvantageous treatment of whistleblowers, and we take the utmost care and attention during investigations of reported matters in order to protect them.
Ensuring Proper Operation of the Whistleblower System
In order to ensure the proper operation of the whistleblower system, the Company reports to an outside attorney regarding the whistleblower's case and the status of the handling of the case, and receives his/her evaluation.
In addition, we report regularly to the Internal Control Committee and the Board of Directors on the outline of the whistleblower's report and its status, and the evaluation by outside attorney, while taking into consideration the confidentiality of the whistleblower.
Through these measures, we ensure the proper operation of our whistleblower system.
Internal Audit
As a part of the internal control system, our Group has established a dedicated organization (Internal Audit Department) within the Company to conduct internal audits (operational audits and internal control evaluations) of each department of the Company and domestic and overseas group companies, in addition to audits by Audit and Supervisory Committee members and audits by accounting auditors. Specific details of internal audits are shown in the table below.
| Operational Audits |
Evaluate, point out, and propose improvements regarding the conformity of business activities with laws, company rules, and other internal regulations, as well as the necessity, effectiveness, and efficiency of business operations. |
|---|---|
| Internal Control Assessment |
Evaluate the effectiveness of internal control over financial reporting, i.e., the status of the development and operation of internal control within the scope of evaluation determined for each fiscal year. |
