The Shindengen Group considers compliance with laws and regulations, such as Competition Laws and Bribery Prevention Laws, to be one of its top priorities. The establishment and timely improvement of effective compliance management procedures and standards are essential. Regular compliance training, as well as keeping up to date with the latest laws and regulations ensures Shindengen can meet its compliance obligations. On October 1, 2015, the Compliance Committee was established with Shindengen’s President as the Chair, and it aims to support the establishment, implementation, and improvement of compliance management at domestic and overseas Group companies.
Committee actions include:
Revised Shindengen Group Guideline for Action
In April 2016, we renewed the “Shindengen Group Guideline for Action” adding in terms regarding the observance of competition laws and bribery regulations. We sent this revised guideline to all employees of Shindengen Group companies under the name of the president and also updated the website, and overseas Group companies translated these guidelines for action into the local languages of their host countries to ensure that all are thoroughly informed and educated.
Competition Law
As the main promotion body, the Compliance Committee continually conducts PDCA cycles to build a compliance program for Competition Laws. As for specific actions, the committee established antitrust law compliance rules, rules for interacting with competitor companies, and a manual for applying for penalty reductions and exemptions (2016); provided cooperative support to overseas group companies on preparing corresponding rules (2017), regularly provides in-house education and training to sales departments.
As for recent actions, we reflected the fine exemption system newly introduced by the 2019 revised Antitrust Law that came into effect in December 2020 by amending the internal rules and related manuals.
Bribery Prevention Actions
As for bribery prevention actions, we provided in-house education and training to sales departments while preparing the in-house rules and manuals (including bribery prevention rules and rules related to providing gifts to foreign government officials), similar actions to those taken for the Competition Laws.
Initiatives for the Personal Information Protection Law
• As for action on the act on the Protection of Personal Information, the Compliance Committee takes the lead and works to respond to relevant laws and regulations in Japan and overseas.
• As a response to the 2020 Personal Data Protection Act, which came into effect on April 1, 2022, we amended our privacy policy and internal rules and newly updated our operations manual, outsourcing contract forms, and other documents. In addition, we consider it important to assess the personal data situation and personal data held by each division and created a data map for Company-wide personal data. Regarding internal education and training, we held two internal online seminars to explain the main revision points of the 2020 Personal Data Protection Act and our responses.
• We regularly assess the content of laws and regulations in each country where overseas Group companies are located and, going forward, will continue working to respond to data protection regulations as a corporate group.
Whistleblowing System and Internal Reporting on Corporate Compliance
The Shindengen Group has established a whistleblower system for early detection and correction of unfair, illegal, or unethical behavior, maintaining social trust, and ensuring the fairness of business operations. In addition, we protect the anonymity of whistleblowers and the confidentiality of the reported information. We protect whistleblowers from receiving unfair treatment due to what they reported. Since April 2022, we have upgraded systems and revised systems in line with the revisions of the Fair Whistleblower Protection Act. The internal Corporate Ethics Hotline connects to Shindengen’s Compliance Office (internal hotline)
and an external lawyer (external hotline), ensuring whistleblower access from not only Shindengen but also Group companies in Japan and overseas.
