Compliance | Governance | Sustainability | Asahi Kasei

Compliance

Policy

The Asahi Kasei Group takes compliance seriously, and fully adheres to laws and regulations that are applicable to each business and function, as well as internal company rules. Each employee is also expected to uphold high ethical standards and respect social norms throughout the course of business activities, acting with sincerity in accordance with our Group Values based on our Group Mission.

Asahi Kasei Group Code of Conduct

The Asahi Kasei Group Code of Conduct serves as a set of standards on compliance that applies to each and every member of the Asahi Kasei Group. The code serves as a foundation for the actions of all members of the Asahi Kasei Group to follow during the course of their day-to-day work activities to fulfill our Group Mission in accordance with our Group Values.
To raise awareness about the Code of Conduct, a booklet is distributed to the Group's officers along with all employees in Japan, and reading sessions covering the Code of Conduct are held at each workplace. In addition, outside of Japan the Code of Conduct is made known to all by distributing a booklet in local languages and through e-learning and other training sessions. This ensures that we are able to realize actions based on a high level of ethical values.

The Asahi Kasei Group Code of Conduct can be downloaded from the link below:

Asahi Kasei Group Code of Conduct

Management framework

We have established the Risk Management & Compliance Committee, which reports directly to the President of Asahi Kasei Corp., in order to reinforce the entire Group's risk management and compliance framework. The committee monitors the state of compliance and management of risks throughout the Asahi Kasei Group. Results of the committee's deliberations, etc., are reported to the Board of Directors.

Compliance Hotline

The Asahi Kasei Group began employing a Compliance Hotline in April 2005 to ensure that any possible ethical lapses which employees may encounter or observe are dealt with swiftly and appropriately. In fiscal 2015, the system was expanded to enable suppliers and their employees to report or consult.

  • There are no restrictions on what can be reported. The hotline receives reports on a broad range of matters, including harassment, human rights violations, and corruption, such as bribery.
  • Reports can both made either anonymously and using one’s real name over the Internet or in writing (addressed to a designated law office).
  • The Asahi Kasei Group has measures in place to prevent the persons submitting reports to be treated unfairly as a result of their report.
    In addition, we strive to protect the confidentiality of the report as well as the personal information of persons submitting reports.

Reports and responses

During fiscal 2018 there were 59 reports and consultations made through the hotline system. None of them regarded significant matters which would affect the performance of operations.
Some 50% of the reports and consultations concerned personal relationships among workplace colleagues. After fact-checking, cautions were issued to relevant personnel as necessary, and monitoring to confirm improvement was performed.

Prevention of bribery

The Asahi Kasei Group endorses the UN Global Compact and has proclaimed that it will "strive to prevent all forms of corruption including coercion and bribery." Corruption including bribery is clearly prohibited within the Asahi Kasei Group Code of Conduct as well.
The Asahi Kasei Group considers bribery to be a particularly important risk factor which could seriously jeopardize our corporate reputation. The Asahi Kasei Group Policies for Prevention of Bribery clarify basic policies to prohibit bribery and procedures to follow to prevent bribery. These policies are made known to the entire Group based on a clear internal framework.

  • 1.Procedures
    Transactions subject to procedures under these regulations directly or indirectly involve counterparties in (1) the public sector (regardless of country) and (2) the private sector in certain countries with commercial bribery regulations including China. Specifically, receiving a meal or gift or providing donations is only permitted after obtaining the advanced screening and approval of the prescribed person in charge of each organization. Due diligence is conducted to check the suitability of business partners from the standpoint of bribery prevention in terms of transactions that fulfill certain formats of concern in terms of bribery prevention, such as contracts with agents and distributors. In addition, business partners are informed of our basic policy on bribery prevention and they are required to sign a pledge or include contractual provisions on the declaration of compliance with anti-bribery related laws.
  • 2.Education
    We provide educational opportunities to employees, including those outside of Japan, in the form of e-learning and in-house training on overall prevention of corruption (bribery, money laundering, fraud, etc.)
  • 3.Monitoring
    We carry out internal audits periodically as well as evaluate and review the management framework for bribery prevention in order to maintain a continuous and effective framework for bribery prevention.
  • 4.Consulting and Reporting
    We have put into place a framework by which employees can consult with a legal department in Japan or at overseas offices or with an outside law office in case uncertainties or doubts arise regarding bribery during the course of their daily work.
    In case an employee discovers a violation of or act that could violate bribery laws, they are required to report the matter immediately to the prescribed person in charge.
    Our whistleblowing system also enables suppliers and their employees to report or consult regarding bribery and other aspects of corruption.
  • 5.Legal violations related to corruption
    In fiscal 2018, there were no cases where an employee was dismissed or subjected to legal proceedings due to corruption.

Political contributions

In terms of political contributions, we have established a system of checks and balances based on company rules to ensure compliance with the Political Funds Control Act. Political contributions are made only after the required pre-approvals are obtained. The company’s political contributions in fiscal 2018 were ¥1,745,000 (Asahi Kasei Group total) and disclosed below.

Compliance with antimonopoly and competition laws

The Asahi Kasei Group Regulation for Management of Compliance with Antimonopoly Law prohibits acts which violate the competition laws of each country. To prevent acts which would constitute or arouse suspicion of participation in a cartel, standards are set for attendance at industry gatherings, and inappropriate contact and information exchange with competitors are prohibited. Furthermore, across-the-board price revisions for products sold in Japan require submission to our Market Compliance Committee which includes the Executive Officer for compliance among its members, confirmation of the reason for the price revision, and confirmation that there is no violation of antimonopoly law prior to implementation.

Compliance with export-related laws

The Asahi Kasei Group thoroughly complies with export-related laws and regulations in accordance with our Export Control Regulation. All exported products are subject to screening for applicability of export restrictions and examination of customers. In the case that a permit is required, application to the Ministry of Economy, Trade, and Industry is made after obtaining internal company approval. To ensure awareness and understanding of the requirements of relevant laws, regulations, and internal company rules, periodic training sessions are held and the related departments undergo paper and onsite audits annually.

Ethical Considerations in Pharmaceutical and Medical Device Development

Asahi Kasei Pharma, which engages in the research and development of pharmaceuticals, and Asahi Kasei Medical, which engages in the development of medical devices, ensure ethical considerations and full compliance with laws and guidelines on animal testing. See below for further details.