Risk and Compliance Management
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 putting in place a risk management framework that includes the Risk & Compliance Committee and Risk Hotline, Mitsui Chemicals is acutely aware of the critical need to have its employees, who drive its risk management framework forward, strictly adhere to all laws and regulations. With this in mind, the Company has undertaken four initiatives in an effort to ensure compliance. In addition to preparing the Compliance Guidebook, we conduct workplace discussions covering case studies of violations of laws and regulations as well as compliance awareness training in order to strengthen the understanding of employees. From a skills and knowledge perspective, we also conduct legal and regulatory compliance training.
The Compliance Guidebook (issued in 2006) summarizes basic points that Group directors, corporate auditors, and employees should consider when carrying out their duties. It is a tool that emphasizes the need to comply with all laws and regulations, a key component of the Mitsui Chemicals Group Action Guidelines. As circumstances dictate, steps are taken to revise the content of the Compliance Guidebook to include specific examples of violations of the laws and regulations of each country as well as instances of bribery or the falsification of data, issues that are attracting widespread media interest in Japan, and to increase awareness within the Group as a whole. We updated the guidebook regularly, and recently added points to bear in mind with regard to company and personal information when using social networking services (SNS).
We have compiled a guidebook on the theme of antitrust laws and corruption laws 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.
Example-based Workplace Discussions on Legal and Regulatory Violations
Mitsui Chemicals and its domestic subsidiaries and affiliates have been organizing example-based workplace discussions on legal and regulatory violations 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 with senior members of staff. 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 other departments. In fiscal 2020, we conducted discussions at 58 company departments and 22 subsidiaries and affiliates.
Compliance Awareness Training
The awareness of individual directors, 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 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 fiscal 2020, compliance awareness training was conducted as part of the new employee training, midcareer employee training and line manager training programs to foster awareness of compliance with laws and regulations, based on case studies and discussions of violations in the Group and other companies.
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 regulations 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
- Finance and taxation
- Intellectual property
- Information management
- Antimonopoly legislation
- Credit control
- Export control
- Purchasing rules
Overseas compliance training
A guidebook on the theme of antitrust laws and corruption laws has been published and distributed throughout the Mitsui Chemicals Group. The Group's regional headquarters for China and the Asia-Pacific region have published their own handbooks on antitrust laws, corruption and bribery that are generally regarded as high risks and has distributed copies to affiliated companies in their respective regions. Training courses on these themes organized by legal professionals are being planned every two years.
Since fiscal 2016, seminars on bribery regulations, antitrust laws and contracts have been held in China, Singapore, Thailand, Malaysia, India and Indonesia, and regular discussion training on cases of compliance violations around the world have been organized.