The Oji Group's Compliance Department (Corporate Governance Division, Oji Holdings Co., Ltd.) formulates policies and measures to promote compliance. The Oji Group Charter of Corporate Behavior, Code of Conduct, and Regulations for Prevention of Corruption are formulated by the Oji Holdings and the Legal Department (also within the Corporate Governance Headquarters), and are reviewed and revised as necessary after their necessity and effectiveness are checked on a regular basis.
We have built a compliance network by staffing compliance managers and compliance promotion leaders at Group’s companies all over the world. These members work together with the Corporate Compliance Department and act as facilitators who help spread measures appropriately to employees of each company. They also strive to raise awareness of compliance among employees by playing the leading role in the compliance promotion activities of each company.
The General Manager of the Corporate Governance Division, who is also the Director in charge of the Corporate Compliance Department, takes a role as the compliance manager and regularly reports the Group’s compliance activities to the Group Management Meeting, Board of Directors, and Audit & Supervisory Board.
Response to Compliance Violations
The Oji Group considers not only violations of laws and regulations to be compliance violations, but also infringements of the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard and ethical violations.
We have a system under which a compliance violation that has occurred within the Group is immediately reported from the department where it occurred to the General Affairs Department, the Corporate Compliance Department, and the General Manager of the Corporate Governance Division, and then to the Group CEO in accordance with the Group Risk Management Regulations.
The Compliance Department plays a central role in dealing with incidents. Particularly important incidents are reported to the Board of Corporate Auditors, opinions are exchanged, and advice is obtained. In cooperation with the Compliance Officers of operating companies and in-house companies, the Compliance Department conducts investigations to confirm the facts, investigates the causes, takes countermeasures, and takes preventive measures. Cases based on the Corporate Ethics Help Line are investigated with due consideration given to the protection of whistleblowers.
Disciplinary action against an officer or employee who has been involved in a compliance violation is considered based on the employment rules, and such a person is punished severely where necessary.
The way a case has been handled and the results of handling it are reported by the General Manager of the Corporate Governance Division to the Group Management Meeting, Board of Directors, and Audit & Supervisory Board.
We also implement measures such as the provision of training as an after-the-fact follow-up measure, as well as monitoring activities including an awareness survey.