Group Code of Conduct
Based on the Group’s management philosophy and company principles, the Group Code of Conduct was established in June 2014 to set forth standards that all Group executives and employees must abide by if the UACJ Group is to be able to move forward as a corporate group that garners even greater trust by society.
Efforts to prepare versions of the Group Code of Conduct in the official languages of the locales of overseas affiliates are moving forward. Including the original Japanese version, the Group Code of Conduct now exists in ten different languages.
The Group Code of Conduct is available online in the various languages in which it has been completed.
The Group Code of Conduct is available in the following languages:
Japanese, English, Chinese, Czech, Indonesian, Thai, Spanish, Vietnamese, Brazilian Portuguese, and Malay.
As part of its compliance education endeavors, the UACJ Group has posted the Group Code of Conduct on the intranet and distributes abridged editions that all executives and rank-and-file employees can keep with them at all times. In fiscal 2018, department-level seminars on the Group Code of Conduct were held for employees of UACJ, 30 Group companies in Japan and 26 Group companies overseas. Afterward, the president of each company pledged to the President of UACJ in writing that they would uphold the Group Code of Conduct.
In fiscal 2018, training was conducted on topics such as information security, Japan’s Personal Information Protection Law, and the EU’s General Data Protection Regulation (GDPR).
Through regular, ongoing measures such as these, UACJ Group strives to ensure sound compliance awareness and understanding of legal provisions throughout its organization.
Internal Reporting System (Corporate Ethics Consultation System)
The UACJ Group operates an internal reporting system (Corporate Ethics Consultation Hotline) the purpose of which is to prevent compliance problems altogether, or discover them early on and swiftly resolve them. This system has internal and external channels that employees can access anonymously. Measures are in place to receive contacts by telephone, postal mail, e-mail, and other means as well. The Anonymous Reporting Board* is another reporting function that we have established to make it easier for employees to report activity they believe or suspect constitutes a compliance violation. The Corporate Ethics Consultation Hotline oversees and appropriately handles all reports of questionable activity from the selection of a unit to investigate the report, to implementation of a formal response. At the same time, it makes clear to relevant employees that the reporting employee and those who cooperate with the investigation are not to suffer any negative consequences from the mere reporting of suspicious activity or cooperation with the investigation. Furthermore, actions are taken to thoroughly protect the reporting and cooperating employees by, for example, confirming that they actually have not been subjected to negative consequences for their actions.
In fiscal 2019, steps will be taken to expand the scope of potential users and further facilitate internal reporting. These steps will result in a common reporting system accessible by executives and rank-and-file employees of Group companies inside and outside Japan as recommended in guidelines issued by Japan’s Consumer Affairs Agency.
* The Anonymous Reporting Board is a system that allows an employee to engage in a dialog anonymously with hotline personnel. The receipt of a report anonymously can make it impossible to adequately investigate the report or provide investigation results and information on problem solutions back to the reporting employee. The UACJ Group has adopted the Anonymous Reporting Board to alleviate such problems.
Hotline Reports Received and Status of Responses
In fiscal 2018, UACJ Corporation received seven reports via the Corporate Ethics Consultation Hotline, while affiliates in Japan received a total of 22. Ten of the reports concerned harassment and the remaining 12 pertained to other matters. Reports from employees willing to provide their names were properly handled, and investigation results and information on corrective measures were provided to the reporting employees.
Reports from employees wishing to remain anonymous were investigated to the extent possible. Those engaging in the improper activity identified were instructed on proper approaches and cautioned regarding their conduct going forward.
Reports received by affiliates were properly responded to by the relevant company, with investigative and other types of assistance from the Company, as needed.
Strict Compliance with the Antimonopoly Act and Protection of Free Competition
Provisions in the UACJ Group Code of Conduct call for fair, transparent, and free competition, and engagement in legitimate business transactions, by specifically prohibiting restraint of competition, abuse of advantageous circumstances, and other such activities. Thorough understanding of these matters is promoted when opportunities are available in training on the code of conduct, job-level training, and on other occasions as well. In addition, all executive officers undergo training on compliance with Japan’s competition laws. In fiscal 2018, seminars were held on Japan’s antimonopoly law and overseas competition laws as part of the training conducted for department heads and newly appointed managers. Outside of Japan, a seminar on competition law was held at the local affiliated in Thailand.
In fiscal 2018, we experienced no violations of either Japan’s Antimonopoly Act or the antimonopoly laws of other countries.
To help ensure that it engages in fair, transparent, and appropriate business transactions, the UACJ Group has included in its Group Code of Conduct provisions specifically prohibiting acts such as bribery and excessive expenditures for entertainment, and thorough understanding of these points is promoted in code of conduct education programs and job-level training. In addition, all UACJ executive officers undergo training on the prevention of corruption.
In fiscal 2018, seminars on bribery prevention were held for department heads and newly appointed managers. A seminar on the same topic was also held at the local affiliate in Thailand.
There were no instances of the acceptance or offering of a bribe, or any other violations of the Group Code of Conduct, in fiscal 2018.
Implementation of Global Guidelines
In fiscal 2018, UACJ’s headquarters formulated the Group’s basic policies on compliance with competition laws and prevention of bribery. It then developed global guidelines to be applied by Group companies throughout the world and created guidelines tailored to the business practices and legal systems of individual countries.
Activities that promote compliance with competition law and prevent corruption should be undertaken at all levels, and it is important for all employees, regardless of their position, to understand this point. The global guidelines, therefore, have been prepared in English and seven other languages to provide employees of Group companies with a version in the local official language.
Prior Authorization of Entertainment and the Exchange of Gifts
In fiscal 2019, a system for the prior authorization of entertainment and the exchange of gifts will be implemented. To prepare for implementation, steps such as disseminating information on the system to all Group companies in Japan, were taken in fiscal 2018.
Anti-Corruption Training at UATH
At UATH*, seminars on competition law and anti-corruption law were held for management-level employees. These seminars were held in the Thai language to help ensure that all participants gain a thorough understanding of these topics.
* UACJ (Thailand) Co., Ltd.
Rejection of Relationships with Antisocial Forces
In its company principles, the UACJ Group requires the strict rejection of relationships with antisocial forces and organizations. Furthermore, through our Group Code of Conduct, we strongly emphasize to all executives and employees that they are not to bend to inappropriate demands by antisocial forces, must remain resolute throughout, and must never engage in any relationship with antisocial forces.
UACJ, in accordance with its internal rules, makes donations and joins organizations only after determining that potential recipients, and organizations the company may join, have no connections to antisocial forces.