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 compliance management framework that includes the Compliance Management Committee and Risk Hotline, Mitsui Chemicals is acutely aware of the critical need to have its employees, who are the driving force of the framework, 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) sets out the President's ideas about the need to comply with all laws and regulations at the beginning and summarizes basic points that Group directors, corporate auditors, and employees should consider when carrying out their duties. Specifically, as circumstances dictate, steps are taken to revise the content of the Compliance Guidebook to gradually add and expand examples of violations of the laws and regulations of each country, instances of bribery or the falsification of product data, issues that are attracting widespread media interest in Japan, as well as points to note with regard to company 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 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 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. In addition, we review examples to be discussed and added LGBT-related harassment examples in cooperation with the Human Resources Division in fiscal 2020. In fiscal 2021, we conducted discussions at 59 company departments and 22 subsidiaries and affiliates.
Examples of Topics of Workplace Discussions on Legal and Regulatory Violations
- Failure to submit notifications required by the regulatory laws
- Product performance falsification
- Price cartel
- Violation of the Subcontracting Law
- Insider trading
- Concealment of misconduct
- Power harassment
- Sexual harassment
- Leakage of company information
- Excessive entertainment, etc.
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 2021, compliance awareness education and 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.
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
- Intellectual property
- Finance and taxation
- Information management
- Antimonopoly legislation
- Credit control
- Export control
- Purchasing rules
Overseas compliance training
A guidebook on the theme of competition law and anti-bribery 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 competition law, anti-Bribery and Corruption that are generally regarded as high risks and has distributed copies to affiliated companies in their respective regions. In addition, training on competition law, anti-Bribery and Corruption, personal information management and company information management and others by lawyers is regularly held in each region.