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.
We will continue to review this Code of Conduct based on the expectations of society and changes in circumstances in order to maintain its effectiveness.
The Asahi Kasei Group Code of Conduct can be downloaded from the link below:
Awareness of Code of Conduct
After the establishment of the Code of Conduct in fiscal 2017, we created booklets containing this Code and distributed them to the executives as well as all domestic employees of our Group. We also spread awareness about the Code of Conduct by checking them against the Code at each workplace and establishing an e-learning course for reviewing the Code (required of new employees; optional for current employees).
In fiscal 2019, to further improve awareness of the Code of Conduct, we began using specific examples of compliance violations and holding discussions about them at each workplace (we plan to do this annually for the duration of the current Medium-term Management Initiative). In addition, we integrated a review of the Code of Conduct into the company training curriculum for new section managers. Further, to confirm the degree of awareness with regard to the Code of Conduct, we issued a Compliance Survey to our 29,572 domestic employees (including contract employees, temporary employees, and part-time employees) and received 27,683 responses (a response rate of 93.6%). Of these, approximately 80% said that they understood the Code of Conduct, confirming that the Code has firmly taken hold.
Overseas, in addition to distributing booklets of the Code of Conduct in various languages, we are steadily working to expand awareness through e-learning, training, and other means, and we are promoting actions that are based on a strong sense of ethics.
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.
Serious Compliance Violations Within Asahi Kasei Group
If a significant compliance violation occurs within our Group, a system is in place whereby the Executive Officer for compliance reports the incident to the Risk Management & Compliance Committee.
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. Reported matters will be investigated by an office consisting of those designated by the Executive Officer for compliance as well as an organized investigation and response team if required. The Executive Officer for compliance reports the status of operations to the Risk Management & Compliance Committee. For serious compliance violations and incidents involving executive officers, the Executive Officer reports to the Board of Corporate Auditors.
■Strict observance of confidentiality
- 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.
- Executives and employees of our Group, business partners and their employees
- 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 be both made either anonymously and using one's real name over the Internet or in writing (addressed to a designated law office).
Reports and responses
During fiscal 2019 there were 55 reports and consultations made through the hotline system. None of them regarded significant matters which would affect the performance of operations.
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.
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.
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.)
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 2019, there were no cases where an employee was dismissed or subjected to legal proceedings due to corruption.
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 2019 were ¥16,030,000 (Asahi Kasei Group total) .
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.