The Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard, which constitute the management philosophy of the Oji Group, clearly state “Wholesome Relationship with Politics and Government” and “Maintenance of an Honest, Wholesome Relationship with Business Partners,” making it mandatory to ensure the transparency of political donations and prohibiting corrupt practices such as illegal contributions and donations as well as bribery. We thus request all the related parties -- our customers, business partners, agents, and competitors -- to understand and support our policy of observing this management philosophy in our business transactions.
Concerning anti-corruption, we recognize improper trading as a type of the Group’s risk 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 addition, we have established the Group Bribery Prevention Regulations and the Guidelines about Bribery in accordance with the Principle 10 (anti-corruption initiatives) of the UN Global Compact to make measures taken within the Group clearer and more specific.
For example, we conduct risk assessment for preventing involvement in corruption through judgment of whether the countries and regions where we operate have bribery risks specific to them, the screening of agents to 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 risk is found.
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.
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.
To inform officers and employees thoroughly of our anti-corruption initiatives, we hold sessions for explaining the Group Bribery Prevention Regulations, with the leading role played by the Corporate Compliance Department of the Corporate Governance Division. In particular, we provide training in regions where there is a possibility of bribery. 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 are published on the official website of Oji Holdings Corporation, and the Group Regulations are on the intranet. The Corporate Code of Conduct and Behavior Standard have also been distributed to all employees in the form of a booklet. See the ESG Data for the amounts of political contributions and donations that were made in FY2018.