At the Oji Group, the Corporate Compliance Department (under the Corporate Governance Division of Oji Holdings Corporation) draws up policies and plans measures for promoting compliance. This department and the Legal Affairs Department (which is also under the Corporate Governance Division) supervise the formulation and review of the Oji Group Corporate Code of Conduct and the Oji Group Behavior Standard, the establishment and revision of anti-corruption rules, and similar matters.
We have built a compliance network by staffing compliance managers and compliance promotion leaders at Group’s consolidated subsidiaries 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
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 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 and the Group Emergency Response Regulations.
For any compliance violation that has occurred, the Corporate Compliance Department plays the leading role in a fact-finding survey, an investigation into the causes, and the implementation of countermeasures and measures for preventing its recurrence, by working together with the compliance managers of the Group company and the COMPANY where it occurred. Where a violation has been revealed by whistleblowing, surveys are to be conducted with due care to protect the whistleblower.
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.