Approach to Compliance

1. Setting a Compliance Committee

Shindengen Group considers compliance with laws and regulations such as Competition Laws and Bribery Prevention Laws as one of its top priorities. Establishment and timely improvement of effective compliance management procedures and standards is essential. Regular compliance training, as well as keeping up to date with the latest laws and regulations ensures Shindengen can meet its compliance obligations. On October 1st 2015, a Compliance Committee was established, with Shindengen’s President as the Chair, and is tasked with managing such compliance efforts.

Committee actions include:

Revised Shindengen Group Action Guidelines

Reviewed focusing on the Competition Laws and Bribery Prevention Laws and updated the Group Action Guidelines accordingly (April 2016)

Competition Law

Prepared competition legal provisions and emergency response manuals by the working group under the compliance committee meeting. Additionally, training workshops are held few times a year by subject experts for overseas subsidiaries’ Presidents, and sales departments.

Bribery Prevention Actions

Developed Anti-Bribery provisions, operational manuals by the working group under the compliance committee meeting and held educational training same as the competition law.

2. Whistleblowing System and Internal Reporting on Corporate Compliance

To ensure Shindengen Group operates to the highest legal and ethical standards, an internal whistle-blowing system has been established. This aims to provide a safe communication channel for employees to report and respond appropriately to illegal and/or unethical conduct. A whistleblower hotline was established which is responded by the internal audit department, and/or an external lawyer. The communication channels are available to domestic group companies. Overseas subsidiaries have similar safe communication channels, and report periodically to head office management.

3. Compliance with the Subcontract Act

Shindengen Group considers compliance with the Subcontract Proceeds Payment Delay Prevention Laws (Subcontract Act), a special Law under the Anti-Monopoly Laws, essential for the promotion of fair trade. Shindengen’s Materials Division is responsible for regular education training sessions, preventative actions, and on-site compliance inspections for all group companies.

  • Compliance Education on Subcontract Act

4. Anti-Social Forces

Shindengen is committed to fulfilling its social responsibilities, by not engaging with any group or individual that endangers or harms society. Any group or individual that endangers or harms society identified internally, or with business partners is ceased immediately. Therefore, we kindly ask our stakeholders to sign the “Memorandum of the Anti-social Forces”.

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