Concerning anti-corruption, we recognize improper trading as a type of risk the Group faces in the Group Risk Management Regulations. It is one of the risks for which the Board of Directors supervises the establishment and implementation of countermeasures.
In accordance with the Principle 10 (the anti-corruption initiatives) of the UN Global Compact, we clearly state that a wholesome relationship with politics and government and the maintenance of an honest, wholesome relationship with our business partners are important to us in the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard, making it mandatory to ensure the transparency of political donations and prohibiting corrupt practices such as illegal contributions and donations as well as bribery.
In addition, we revised the Group Bribery Prevention Regulations and Guidelines about Bribery in FY2020 with the goal of developing and enhancing the existing system to further ensure the prevention of corrupt practices, a goal set out in the Global Compact, in which the Oji Group participates.*
In addition to the detailed rules about providing benefits that were established to prevent bribery, we added new regulations, principally prohibiting officers and employees of the Group from “receiving benefits” (receiving “hospitality” or “gifts” from business associates) that arouse suspicion of the acceptance of bribes from business associates in order to build good healthy relationships with business associates, making measures taken within the Group clearer and more specific.
For example, we conduct risk assessment for preventing involvement in corruption through our judgment of the bribery risks specific to each country and region where we operate, the screening 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 where risks are identified.
In addition, through internal audits, we regularly check each Group company from the viewpoint of preventing corruption
We consider disciplinary action based on the employment rules against any officer or employee who is involved in corruption in business transactions, such as bribery, and punish them severely.
Dissemination among employees
To ensure that officers and employees are thoroughly informed of our anti-corruption initiatives, the Corporate Compliance Department of the Corporate Governance Division plays a leading role in the sessions that we hold to explain the Regulations. In particular, we provide training in regions where there is a possibility that bribery may occur. In addition, each Group company has a read-through of the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard at 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 Benefit), the Group Anti-Bribery and Anti-Corruption Regulations (Receiving Benefit) and the related Guidelines are on the intranet and can be viewed by officers and employees.
In FY2018, no officers or employees committed violations related to anti-corruption and there were no penalty charges, surcharges, or settlement money related to corruption.
See the ESG Data for the amounts of political contributions and donations.
* The Group Bribery Prevention Regulations and Guidelines about Bribery were revised in FY2020.