1. Setting up the Compliance Committee

The Shindengen Group considers compliance with laws and regulations, such as Competition Laws and Bribery Prevention Laws, as one of its top priorities. The 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 1, 2015, the Compliance Committee was established with Shindengen’s President as the Chair, and it aims to support the establishment, implementation, and improvement of compliance management at domestic and overseas Group companies.

Committee actions include

•Revised Shindengen Group Guideline for Action

In April 2016, we renewed the “Shindengen Group Guideline for Action” adding in terms regarding the observance of competition laws and bribery regulations. We sent this revised guideline to all employees of Shindengen Group companies under the name of the chairperson and also updated the website.
In FY2017, overseas Group companies translated these guidelines for action into the local languages of their host countries to ensure that all are thoroughly informed and educated.

Competition Law

In FY2016, the working team of the Compliance Committee took the initiative to establish internal rules and emergency response manuals to ensure compliance with relevant laws.
In FY2017, the Compliance Committee Secretariat supported the establishment of compliance programs at overseas Group companies and the development of regulations, etc., for each Group company. The subject activities were almost completed.
While implementing competition law education and training on an ongoing basis, in FY2017 the Secretariat focused on business combination and conducted in-house training for staff divisions and sales departments concerning notes on pre-notification systems, etc., to authorities.
In FY2018, employees at sales and other departments underwent training on competition laws that focused on what led to the latest incidents associated with overseas competition laws, risks arising from involvement in cartels (fines and criminal penalties) and leniency systems as well as other relevant topics, such as matters to be noted in the course of exchanging intelligence with competitors.

•Bribery Prevention Actions

In FY2016, as with the competition law, the working team set up anti-bribery provisions and prepared operational manuals, etc.
In FY2017, we implemented the same support as for the competition law, and the classifications, etc., of overseas group companies were upgraded. We also conducted in-house training on bribery regulation in the United States, the United Kingdom and China for the sales department.

•Initiatives for the Personal Information Protection Law

With the enforcement of Japan’s revised Personal Information Protection Law, we created a new working team, mapped personal data and developed regulations, etc.
Based on the enforcement of the EU General Data Protection Rule (GDPR), the Secretariat and the European subsidiary (Shindengen UK) are working together to grasp the contents of laws, regulations and guidelines while seeking advice from experts and have implemented practical measures, such as the data mapping of Shindengen UK. In addition, when personal data gleaned in the European Economic Area (EEA) is transferred to a Group sales subsidiary operating outside Japan, we have made it a rule to require that said subsidiary sign a contract containing Shindengen Group standard contract clauses (SCC) aimed at sufficiently safeguarding personal data as required by the GDPR.
In January 2018, we invited experts on education and training on the Personal Information Protection Law, including the GDPR, to address board members and department managers.
In FY2019, employees at sales departments underwent training for to ensure comprehension of the basic rules of the GDPR. In addition, the Compliance Committee works to share information on and provide explanations about global trends in personal data protection rules and Shindengen’s initiatives through the secretariat. Going forward, we will continue to conduct in-house training, updating manuals to prepare for data leaks, responding to regulations in various countries, and offering support as needed to Group companies.
Shindengen’s “Privacy Policy” recognizes protection of customer privacy and personal information is of the utmost importance. This Privacy Policy was updated in July 2019.

2.Whistleblowing System and Internal Reporting on Corporate Compliance

To ensure the Shindengen Group operates at the highest legal and ethical standards, an internal whistle-blowing system has been established. The system aims to provide a safe communication channel for employees to report and respond appropriately to illegal and/or unethical conduct. A whistleblower hotline has been established, with domestic Group companies using Shindengen’s Internal Audit Department and an external lawyer as communication channels for reporting and counseling. Overseas subsidiaries establish their own in-house channels and use Shindengen’s Internal Audit Department as a communication channel for reporting and counseling.

3. Compliance with the Subcontract Act

The 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 Purchasing Department is responsible for regular education training sessions, preventive actions, and on-site compliance inspections for all group companies.

4. Anti-Social Forces

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