• System
• Whistle-blowing system in compliance with the Whistleblower Protection Act
• Monitoring of the Status of Compliance
• Response to Compliance Violations
• Dissemination of the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard
• Activities to Foster an Awareness of Business Ethics and Compliance
• Data

System

The Oji Group's Corporate Compliance Department (in the Corporate Governance Division of Oji Holdings Co., Ltd.) formulates policies and measures to uphold a high standard of ethics in its businesses and ensure compliance. The Oji Group Corporate Code of Conduct, Behavior Standard and Regulations for Prevention of Corruption are formulated by the Corporate Compliance Department and the Legal Affairs Department (also within the Corporate Governance Division), and they are reviewed and revised as necessary following the regular examination of their necessity and effectiveness.

We have established a compliance network by positioning compliance managers and compliance promotion leaders at Group companies all over the world. These team members work together with the Corporate Compliance Department and act as facilitators who help share measures appropriately with employees of each company. They also strive to increase employees’ compliance awareness by playing a leading role in the compliance activities of each company.

The person responsible for business ethics and compliance is the President and Representative Director of the Board of Oji Holdings.
The General Manager of the Corporate Governance Division (Executive Officer) is responsible for overseeing the implementation of the Group's compliance activities.
The General Manager of the Corporate Governance Division (Executive Officer) reports to the President and Representative Director regarding the Group's compliance activities, receives instructions from the President and Representative Director and their activities are supervised by the President and Representative Director on a daily basis.
When important matters are raised, the General Manager of the Corporate Governance Division submits proposals and reports to the Group Management Meeting, the Board of Directors, and the Audit & Supervisory Board in line with instructions from the President and Representative Director.

Oji Group Compliance Promotion Structure

Whistle-blowing system in compliance with the Whistleblower Protection Act

The Business Ethics Helpline is available to all executives, employees (including part-time and temporary employees) and as well as retired employees. The purpose of the helpline is to prevent the violation of laws and misconduct (including labor-related issues, sexual harassment and power harassment), detect them at early stages and correct them.
In addition, we have set up reporting offices internally (within the Corporate Compliance Department of Oji Holdings) and externally (at a lawyer's office). We also receive reports from and consult with the executives and employees of our business partners, job applicants, interns, other trainees and former trainees. We will quickly identify and correct any improper conduct.
Whistleblowers are legally protected as detailed in the Group Internal Whistleblowing Regulations, which stipulate measures for protecting whistleblowers as stipulated by the Whistleblower Protection Act. The information provided by whistleblowers is kept strictly confidential, any retaliation against or any other prejudicial treatment of whistleblowers is prohibited and whistleblowers may remain anonymous.
This system is described in the Oji Group Corporate of Conduct and the Oji Group Behavior Standard and information about this system is distributed to all officers and employees. Additionally, we disclose information about this system on the intranet so that any conduct that violates these rules or any risks of such behavior occurring will be promptly reported. The Company also makes this information known every month through its Compliance News newsletter.
We have established the Group's whistleblowing regulations which are in line with the Whistleblower Protection Act to ensure that all Group companies are thoroughly familiar with these regulations. The Group Internal Whistleblowing Regulations prohibit the prejudicial treatment toward whistleblowers and stipulate the structure of the whistleblowing system, the information management procedures for maintaining confidentiality during investigations and the penalties for violating these regulations.
In addition, we accept reports from sources outside our companies through the Contact Us (Category: Compliance) form on our website when officers or employees may be involved in compliance violations. People submitting reports may remain anonymous and the information we receive is treated with the strictest of confidentiality, as with employees.
The people receiving the information submitted via the Contact Us (Category: Compliance) form are members of the Corporate Compliance Department who are committed to acquiring necessary knowledge and skills by attending external training sessions, participating in workshops, and holding regular workshops with other consultants.

In FY2023, there were a total of 129 reports and requests for consultation submitted to the Oji Group Business Ethics Helpline. The majority of these reports or requests for consultation were regarding harassment or the work environment/human relationships, including consultations regarding miscommunication with a supervisor or coworker in the workplace in everyday work. Depending on the nature of the subject matter of the report or request for consultation, in principle, the Corporate Compliance Department staff or the compliance leader of the company investigates the matter carefully from a fair perspective and acts to solve the problem and resolve concerns, including the referral of matters to a lawyer or other third party.

Monitoring of the Status of Compliance

The Internal Audit Department conducts regular audits, and if problems are identified, implements countermeasures to individually address issues and implements other detailed responses to ensure that compliance is firmly established. In addition, a compliance awareness survey of all Oji Group officers and employees is conducted every other year in Japan to monitor the status of compliance at each work site.

Response to Compliance Violations

In the Oji Group, compliance violations are not only violations of laws and regulations, but also infringements of the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard, and violations of the Group’s ethical standards.
When a compliance violation occurs within the Group, the department where it occurred reports immediately to the General Affairs Department, the Corporate Compliance Department, the Executive Officer and the General Manager of the Corporate Governance Division before then reporting to the Group CEO in line with the Group Risk Management Regulations.
The Corporate Compliance Department takes the lead in investigating the facts and the causes of incidents and leads the implementation of measures to prevent recurrence in cooperation with the compliance officers of the operating companies and the companies where the incidents occurred.
When matters are reported to the Business Ethics Helpline, investigations are carried out in compliance with the Whistleblower Protection Act, carefully ensuring that whistleblowers are protected.
If necessary, the Oji Group considers imposing disciplinary actions regarding officers and employees involved in compliance violations in line with the employment regulations. The Group will take strict action if necessary.
The Executive Officer and General Manager of the Corporate Governance Division will meet with the Group Management Meeting, the Board of Directors, and the Audit & Supervisory Board to report on the status and results of the handling of incidents, including reports related to whistleblowing reports in line with the Group Whistleblowing Regulations.
In addition, follow-up training and monitoring measures, such as awareness surveys, are conducted at the relevant workplaces.

Dissemination of the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard

The Corporate Compliance Department provides a booklet containing the Oji Group Corporate of Conduct and the Oji Group Behavior Standard (revised on October 1st, 2020) to all Group officers and employees (including part-time and temporary employees).
The Corporate Compliance Department has prepared explanatory and educational materials on the basic concept, explanations of the articles and text of the Oji Group Corporate of Conduct and the Oji Group Behavior Standard , and points to check regarding them. These materials have been used in the provision of education at compliance meetings at all of the workplaces of the domestic offices of the Oji Group.
The Corporate Compliance Department initially translated the Oji Group Corporate Code of Conduct, the Oji Group Behavior Standard and educational materials into 12 languages for overseas employees. It continues to translate them into more languages as necessary. The translations of the education materials are distributed as part of the Compliance News newsletter regularly published by the Corporate Compliance Department for Japan and overseas workplaces and they are used at workplace compliance meetings at Group companies in order to disseminate the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard and encourage employees to practice the standard.

Activities to Foster an Awareness of Business Ethics and Compliance

The Corporate Compliance Department of Oji Holdings ensures compliance by providing compliance training and publishing newsletters. The compliance leaders of the Group companies lead regular business ethics and compliance meetings and training sessions on harassment and other issues for all officers and employees (including part-time and temporary employees) in each workplace. The Oji Group strives to elevate the ethical standards upheld in its businesses and increase compliance awareness through the combination of these activities.

Training

We conduct corporate ethics and compliance training by educating new managers, new employees and other employees at different levels, as well as regular in-house training sessions on harassment, the Act against Delay in Payment of Subcontract Proceeds, the Anti-Monopoly Act and anti-bribery measures.

Information Dissemination

Data

In FY2023, there were a total of 129 reports and requests for consultation submitted to the Oji Group Business Ethics Helpline. There have been no significant compliance violations that damaged the Oji Group’s corporate value or adversely affected its management.

• ESG Data