As an indication of the priority given to compliance with laws and regulations over any pursuit of profit, the Mitsui Chemicals Group has identified compliance with all laws and regulations as the first item in the Action Guidelines formulated in February 2006. In addition to establishing a compliance management system, we believe that it is important to thoroughly educate each and every employee that operates the system, and we will implement educational measures throughout the Group to raise awareness and promote knowledge of compliance.
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Compliance Management
Compliance training
Communicating top messages
In January 2023, President & CEO Hashimoto communicated a message to the directors and corporate auditors and employees of the Group regarding the importance of compliance. In addition, we featured a relevant dialogue with our corporate lawyer in an internal newsletter. We will continue to communicate top messages from the management of the Company and each company of our Group.
Compliance Guidebook
The Compliance Guidebook (issued in 2006) sets out the President & CEO's ideas about the need to comply with all laws and regulations at the beginning and summarizes basic points that Group directors and corporate auditors, and employees should consider when carrying out their duties. Specifically, we have written and made timely revisions such as adding and expanding the list of cases of bribery, product data falsification, infringement of intellectual property rights, and other violations that have been identified as problems under the laws and regulations of different countries and in the domestic media coverage, as well as things to keep in mind regarding corporate and personal information when using social media. The content of the Compliance Guidebook also states that it is prohibited to have any relationship with anti-social forces and commit acts that cause a conflict of interest, including receiving any personal benefit that may cause a loss in the profit of the company, to increase awareness throughout the Group.
We have compiled a guidebook on the theme of antitrust laws and bribery prevention for the Asia-Pacific region and added a Chinese version containing information on Chinese laws and regulations and risks to the Japanese and English versions.
Compliance Guidebook (Excerpt)
- Size
- 86 KB
Workplace discussions covering case studies of violations of laws and regulations
Mitsui Chemicals and its domestic subsidiaries and affiliates have been organizing workplace discussions covering case studies of violations of laws and regulations since fiscal 2008. These discussions involve members of staff in each workplace discussing examples of compliance violations at Mitsui Chemicals and at other companies, with a focus on the causes, preventive measures, and the potential for similar occurrences in their own workplace. The aim is to raise awareness of legal and regulatory compliance and reinforce interactive communication between staff and their managers. Discussions have received a positive response in many of our workplaces, with some departments voluntarily increasing the frequency of discussion sessions and others picking out examples of particularly relevant violations at their departments. We also updated the examples to discuss, adding cases of quality data falsification, illicit gain, and inadequacy of information management in fiscal 2023. In fiscal 2023, in addition to 68 company departments and 26 domestic affiliates, we expanded the program overseas for the first time to 32 overseas affiliates.
Examples of Topics of Workplace Discussions of Violations of Laws and Regulations
- Falsification of quality data
- Illicit gains
- Bribery
- Failure to submit notifications required by the regulatory laws
- Price cartels
- Violation of the Subcontracting Law
- Insider trading
- Concealment of misconduct
- Abuse of authority
- Sexual harassment
- SOGI harassment
- Leakage of company information
- Excessive business entertainment, etc.
Stratified training on compliance
The awareness of individual directors and corporate auditors, and employees is the most important factor to ensure compliance. The required level of awareness varies however depending on each individual's position within the Company. We therefore tailor the contents of compliance awareness education and training to suit every level, from new recruits to employees newly promoted to a management position, newly appointed line managers, and each management rank. In FY2023, we provided compliance awareness education and training to new recruits, mid-career employees who just joined the Company, and to newly appointed line managers, directors, and corporate auditors of subsidiaries and affiliates. In addition, we also provided training to newly appointed presidents of affiliates regarding the roles that they are required to perform for compliance management and measures being promoted throughout the Group.
Our goal is for individuals at every level to take the initiative and set an example for others, thereby raising levels of compliance awareness throughout the Group and creating a more open corporate culture.
Legal and Regulatory Compliance Training
Here at the Mitsui Chemicals Group, we organize legal and regulatory compliance training in order to improve employees' knowledge. Training is provided via e-learning or group training sessions, both of which cover specific laws and internal rules that our employees need to be aware of in order to carry out their duties. We also organize customized training sessions for individual divisions or subsidiaries and affiliates.
Required subjects vary depending on the contents of each employee's duties. We also require employees to re-take courses on a regular basis to ensure that they are aware of recent developments. Participation in these training initiatives is audited by the Internal Control Division.
e-Learning and Group Training Themes
- Industrial safety and health legislation
- Process safety legislation
- Environmental legislation
- Quality control
- Harassment
- Intellectual property (patent, copyright, and trademark)
- Finance and taxation
- Information management
- Contracts
- Antimonopoly legislation
- Credit control
- Export control
- Purchasing rules
Overseas compliance training
A Compliance Guidebook on the competition law and bribery prevention has been published and distributed throughout the Mitsui Chemicals Group. In addition, the China regional headquarters and the Asia-Pacific regional headquarters have individually prepared handbooks on the competition law, bribery, and corruption that are considered particularly high-risk and have distributed them to local subsidiaries and affiliates. In addition, training on competition law, bribery prevention, personal information management and company information management and others by lawyers is regularly held in each region.