The Shindengen Group considers strict compliance with competition and anti-bribery laws and regulations in Japan and also in the countries of our overseas group companies as one of its top priorities. The Compliance Committee chaired by the President was formed in order to establish, maintain, enhance, supervise, and improve compliance management at Shindengen Electric Manufacturing Co., Ltd., and to support the establishment, maintenance, enhancement, and improvement of compliance management at group companies in Japan and overseas. To date, the Committee has performed the following activities:
Revised Shindengen Group Guideline for Action
We sent this revised guideline to all employees of Shindengen Group companies via our intranet concerning actions to be observed primarily under competition laws and bribery regulations. Our overseas Group companies translated the Guideline for Action into the local language of their host country to ensure that all are thoroughly informed and educated.
Competition Law Actions
As the main promotion body, the Compliance Committee continually conducts PDCA cycles to build a compliance program for Competition Laws. Specifically, the Committee: established rules for complying with antitrust laws, rules for interacting with competitor companies, and a manual for applying for penalty reductions and exemptions; provided cooperative support to overseas group companies on preparing corresponding rules; and regularly provides in-house education and training to sales departments.
The Committee also incorporated the penalty exemption and reduction system and amended the internal rules and manuals relating to the revised Antitrust Law that came into effect in December 2020.
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 or benefits to foreign government officials), similar actions to those taken for the Competition Laws.
Initiatives for the Act on the Protection of Personal Information
• 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 Corporate Ethics Hotline
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 revised our systems and consolidated our frameworks in line with the revisions of the Whistleblower Protection Act. The internal Corporate Ethics Hotline connects to Shindengen’s Legal Compliance Department (internal hotline) and an external lawyer (external hotline), ensuring whistleblower access from not only Shindengen Electric Manufacturing Co., Ltd. but also Group companies in Japan and overseas.
