Compliance

Group Compliance

“Our Commitment” states the principles of our conduct which we should adhere to in our business activities that have diverse points of contact with society. The “Kuraray Group Code of Conduct” serves as guidelines to implement the commitment in performing day-to-day work. The President has declared that we will comply with laws and regulations and “Our Commitment” under all circumstances. To share these principles and commitments among all Kuraray Group employees throughout the world, the Compliance Handbook has been compiled containing the foregoing declaration by the President and explanations of the “Kuraray Group Code of Conduct” and distributed to all employees in Japan and overseas.
　In 2021, we renewed the handbook with a user-friendly design to make it accessible for all employees. We localized the handbook into twelve languages and distributed it to Group companies in Japan and overseas.
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In addition, we have appointed compliance officers at plants and overseas offices of Kuraray and Group companies and have organized regional compliance committees. Since fiscal 2019, we have linked the timing of the activities of the regional compliance committee and Risk Management and Compliance Committee to raise awareness of compliance throughout the Group.

Whistleblower System

The Kuraray Group has the Kuraray Group Employee Counseling Room in place for all employees of the Kuraray Group in Japan (including contract employees, temporary employees, and part-time employees) as a whistleblower system to prevent or detect and resolve compliance violations at an early stage.

The whistleblower system handles all issues on compliance reported from employees, such as business transaction in general (e.g., bribery/corruption), violation of company rules, and personnel affairs including respect for human rights and harassment. In 2023, the Kuraray Group’s Employee Counseling Room received 31 consultations in Japan.
　In addition to above, we established the Global Compliance Hotline, making it accessible to all group employees worldwide, in response to the rapid progress of globalization.
　We replaced the Audit and Supervisory Board Hotline, established as a contact for whistleblowers independent of executive management, with a governance hotline whose point of contact is an external law office that differs from a corporate consultancy. The new framework began operating in January 2023.

As established by the Guideline for the Operation of the Kuraray Group Employee Counseling Room and the Guideline for the Operation of the Global Compliance Hotline, they can report anonymously and are protected from any disadvantageous treatment that may occur due to the report.
　In addition, following the June 2022 amendment of Japan’s Whistleblower Protection Act, the contact person who receive information that can identify persons consulting or reporting has been individually designated as a Whistleblower Response Worker.

Thorough Risk Management and Compliance Measures

Preventing Leakage of Confidential Information

In June 2022, Kuraray appointed a person in charge of Confidential Information Management and formed Confidential Information Management Team. Furthermore, in order to strengthen the management of confidential information, the Confidential Information Management Team of the General Affairs and Human Resources Division will be reorganized into the Confidential Information Management Group in January 2024. As measures against unauthorized access, the team has strengthened network monitoring, introduced a high-security storage system, and developed an IT incident response system. At the same time, Kuraray Group Confidential Information Management policy has been implemented globally, and employees have received further strengthen information security and tighten the information management system by conducting e-learning-based information security education and suspicious e-mail response training for employees.

Compliance with the Antitrust Law

In order to establish an effective antitrust Group-wide compliance program, the Kuraray Group continues to monitor the compliance framework in high-risk businesses and areas and took measures such as providing education and training to officers and employees and conducting an annual audit of public bid projects. The entire Kuraray Group will steadily implement the Antitrust Law Compliance Program to prevent Antitrust Law violations and monitor compliance status.

Anti-Bribery Initiatives

In the Kuraray Group Code of Conduct, action guidelines to prevent bribery and that cover the handling of donations and gifts are declared, and basic policies against bribery are set forth in the Kuraray Group Global Anti-Bribery Policy. In accordance with these policies, we are developing and reinforcing a bribery prevention framework at the Group level by managing of entertainment and gifts etc. and assessing and managing bribery risks through third parties such as agents (including the countries and regions where third parties are employed, the existence of contacts with public officials, risk assessment and approval procedures based on prior investigations of such third parties, and obtaining representations and warranties regarding legal compliance in contracts and covenants), providing education and training to directors, officers, and employees.

Compliance Seminar

Since 2017, departmental compliance education and seminars have been provided once a year to all Group employees in Japan (including contract employees, temporary employees, and part-time employees), with the aim of improving awareness of compliance and fostering an open organization within the department. In 2023, we held an online compliance seminar by an external instructor for general managers of Group companies in Japan. The seminar focused on the theme of "work-life balance," and participants learned through discussions that elicited voluntary and proactive comments and opinions. Seminar participants then followed the procedures they learned at the seminar in their own departments and held departmental discussions with all department members..

Governance