Policy
In accordance with Principle 10 of the UN Global Compact (anti-corruption initiatives), we clearly state that the prevention of all forms of corruption, appropriate relationships with politicians and governments and the maintenance of honest, appropriate relationships with business partners are important to us in the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard which were established by the Board of Directors.
In addition, we have revised our Group Anti-Bribery and Anti-Corruption Regulations and related guidelines to ensure the transparency of political contributions, prohibit illegal grants and donations and prohibit bribery and other forms of corruption.
Since April 2020, in addition to the detailed rules regarding the provision of benefits that were established to prevent bribery, we added new regulations, principally prohibiting officers and employees of the Group from receiving benefits (hospitality or gifts from business associates) that may arouse suspicion of bribery from business associates in order to build good healthy relationships with business associates, making the measures taken within the Group clearer and more specific.
- * The Group Bribery Prevention Regulations and Guidelines about Bribery were revised in FY2020.
Structure
Concerning anti-corruption, we recognized as a group risk in the "Group Risk Management Regulations," which stipulate the prevention of all forms of corrupt activities as types of fraudulent transactions. It is one of the risks for which the Board of Directors supervises the establishment and implementation of countermeasures.
Whistle-blowing system
We also accept whistleblowing about misconduct, including bribery and other acts of corruption, at the Business Ethics Helpline, our whistleblowing system that is compliant with the Whistleblower Protection Act.
Risk assessment
For example, we conduct risk assessments to prevent involvement in corruption through our evaluation of the bribery risks specific to each country and region in which we operate, the evaluation of the agents we hire, application and review procedures related to the granting of benefits and application procedures related to political contributions and donations. We establish and operate a system that makes transactions impossible when risks are identified.
Furthermore, through internal audits, we regularly examine each Group company from the viewpoint of preventing corruption, and consider disciplinary actions in line with the employment rules when any officer or employee has been involved in corruption in their business transactions, such as bribery. We will punish officers and employees severely when such actions are discovered.
Dissemination among employees
To ensure that officers and employees are thoroughly informed of our anti-corruption initiatives, the Corporate Compliance Department of Oji Holdings plays a leading role in sessions held to explain the regulations. In particular, we provide training in regions where there is the possibility that bribery may occur. In addition, each Group company holds read-throughs the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard during regular compliance meetings in their efforts to keep the importance of sound trading in mind.
The Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard have been distributed to all officers and employees in the form of a booklet and they have also been published on the official website of Oji Holdings Corporation. In addition, the Group Anti-Bribery and Anti-Corruption Regulations (Providing Benefits), the Group Anti-Bribery and Anti- Corruption Regulations (Receiving Benefits) and the related guidelines are on the intranet and can be viewed by officers and employees.
Data
In FY2023, there were no employee terminations resulting from violations of the anti-corruption policy and no penalties, surcharges, or settlements paid related to corruption.
See the ESG Data for the amounts of political contributions and donations.