Fair Operating Practices

Fair Competition

The Sanwa Group conducts fair business activities based on proper corporate ethics without ever engaging in unfair practices that restrict competition or improper transactions.


  • Training on cease and desist measures in the Kinki region (202 participants in FY2023)
    As one response to the cease and desist order for adjusting the acceptance of orders in the Kinki region, every year in-house lecturers provide training to sales personnel and the Audit Department conducts audits of Sanwa Shutter Corporation in the six prefectures in the Kinki region to ensure compliance with antitrust laws and other laws and regulations related to our operations.
  • In FY2005, we published the Antitrust Law Guidebook to deepen employees’ understanding of antitrust laws and to encourage fair operating practices as well as legal compliance(Revised in October 2020).
  • In February 2011, we established the Guidelines on Regulations Concerning Contact with Associates from Industry Peers to prevent acts or suspected acts that violate antitrust laws(Revised in November 2020).



The Sanwa Group comprehensively covers the topic of corruption in its Compliance Code of Conduct and Anti-Bribery Guidelines, which sets forth behavioral standards for executive officers and employees, in an effort to prevent all kinds of corrupt practices from happening in the course of daily operations. The Sanwa Group complies with anti-corruption laws and regulations, and conducts business activities in good faith, without ever engaging in unfair practices such as bribery, provision of inappropriate benefits such as gifts or entertainment in violation of laws, regulations, or social norms, embezzlement, or money laundering, etc.

The Sanwa Group has introduced rules, standards and strict internal control procedures, and conducts transactions with other companies in Japan and overseas with fairness and transparency. In accordance with internal rules that comprehensively cover corruption prevention, we stipulate procedures for entertaining and gift-giving to business partners, government officials and others and prohibit “facilitation payments,” (payments of small sums not based on laws or regulations requested to facilitate the progress of administrative procedures) to government officials to expedite official procedures. In addition, we will never make fraudulent or inappropriate donations or contributions in violation of relevant laws or internal regulations.

We have established an internal whistleblowing system in Japan, the U.S., Europe and Asia to provide internal checks and balance functions. The internal whistleblower system allows employees to report legal violations, infringements of human rights, acts of harassment, and corruption, including bribery and unfair business practices. To quickly detect all forms of corruption and violations of compliance rules, including suspicious acts, reports can be made anonymously and are guaranteed to be handled confidentially. We prohibit retaliation and any other adverse treatment of whistleblowers.


Sanwa Holdings’ Audit Department looks closely at any potential risk of corrupt practices in the course of its audits and makes assessments pertaining to such risks . We also maintain and operate compliance systems at overseas Group companies based on the legal system of each country and the circumstances at each company. In addition, we carry out comprehensive and exhaustive due diligence pertaining to corruption prevention before entering into contractual relationships such as M&A.
For serious violations of compliance such as bribery or corruption, the Personnel Committee discusses and deliberates whether to take disciplinary action and measures to prevent recurrence. All matters related to such inappropriate behavior, including bribery and corruption, are under the Board of Directors' oversight. There were no cases of corrupt practice that led to legal action in FY2022.


To instill anticorruption policies Groupwide, we make corruption known to all employees as well as how to prevent it through the Sanwa Group Compliance Code of Conduct and the Anti-Bribery Guidelines. In the Compliance Code of Conduct & Casebook containing the Compliance Code of Conduct and specific compliance cases that could occur in daily operations, bribery and corruption prevention are comprehensively examined using case studies. while we make employees further aware of these issues through e-learning (with quizzes) and the Group newsletter. In addition, managerial staff at Group companies in Japan undergo compliance training, including on the topic of anticorruption, every other year.

In addition, we have identified China, Vietnam, Thailand and Indonesia as regions that may be at higher risk based on a Corruption Perceptions Index (CPI) score of less than 50 as published by Transparency International, and we strive to prevent corruption of any kind in these places through training prior to overseas assignments and training on compliance conducted locally.

Compliance Code of Conduct (excerpts)

Fundamental Attitude

The Sanwa Group, with each individual having a sense of self-awareness and pride and conducting himself/herself with propriety, behaves as a corporate citizen who complies with the law, thus gaining the confidence of society.

  1. We will comply with all laws and regulations of the countries and regions where we conduct business.
  2. We will conduct fair and free transactions with all business partners, and will not engage in bid-rigging, cartels or any other actions that violate competition-related laws and regulations, including actions that could constitute abuse of a superior position under the Antimonopoly Act.
  3. We will not engage in insider trading, or actions suspected of constituting insider trading, such as trading stocks or other securities using internal company information or non-public information of publicly listed business partners.
  4. We will act with good sense regarding business-related customs and courtesies such as business entertainment and gifts, and will neither offer benefits contrary to laws and regulations, social norms or morals, nor accept offers of such benefits.
  5. We will not engage in actions such as requesting business entertainment, gifts, money or other benefits from business partners for our own gain.
  6. We will not offer benefits that constitute bribery, such as providing entertainment, gifts, money or other benefits to public servants, government officials or anyone in an equivalent position.
  7. We take care to maintain sound relationships with governments and administrations, and will not make illegal or inappropriate donations or contributions that violate related laws and regulations, company regulations, or other relevant rules.
  8. In conducting our global business activities, we will comply with laws and regulations related to imports and exports in Japan and other countries, and will not engage in indirect imports or transactions via third parties for the purpose of avoiding the application of such laws and regulations.6) We do not engage in any activities (installing an officer or getting a place in a firm in competition with the Sanwa Group, or transactions which are in competition) for which there would be a conflict of interest between individuals and the Sanwa Group, or any activities where there is concern they might be conflict. If such a situation arises, or there is concern it might arise, it should be reported and discussed with the supervisor or concerned department and proper instructions received.
  9. We do not engage in any activities (installing an officer or getting a place in a firm in competition with the Sanwa Group, or transactions which are in competition) for which there would be a conflict of interest between individuals and the Sanwa Group, or any activities where there is concern they might be conflict. If such a situation arises, or there is concern it might arise, it should be reported and discussed with the supervisor or concerned department and proper instructions received.
  10. We follow common labor regulations and other internal company regulations, and do not conduct political, ideological, or religious activities on company premises without permission. Furthermore, even if conducted outside the company, it must be based on personal name. Company name or official position cannot be used for such activities.

For full version
For Chinese version (simplified)
For Chinese version (traditional)

Anti-Bribery Guidelines(summary)

These Guidelines detail specific measures for further enhancing the Group’s anti-bribery initiatives based on the Sanwa Group Compliance Code of Conduct.

  1. Prohibition of Bribes to Public Officials
    The Sanwa Group shall not seek any benefits that could only be obtained through bribery of public officials. Moreover, the Sanwa Group shall not give or offer entertainment, gifts or other benefits to public officials in any country. In the event of provision of benefits mentioned in the above paragraph are requested by a public official in any country, the Sanwa Group shall firmly refuse the request.
  2. Prohibition of Bribes to Individuals who are not Public Officials
    The Sanwa Group shall not seek any benefits that could only be obtained through bribery or other wrongful means. Any entertainment, gifts, etc., the Sanwa Group provides to business partners who are not public officials shall be provided in compliance with the laws of each country and within the scope of socially accepted norms.
  3. Prohibition of Acceptance of Entertainment and Gifts
    The Sanwa Group shall never request or accept entertainment, gifts or other benefits beyond the scope of social courtesy from business partners. Moreover, the Sanwa Group shall not engage in illegal acts (providing advantage in commercial transactions, giving a favorable evaluation or endorsement, providing confidential information, not disclosing misconduct or scandals, etc.) for the benefit of a family member, friend, close relative, or other close associates of an employee. Moreover, the Sanwa Group shall not request, promise to accept, or accept any entertainment, gifts, favors, money or other benefits in relation to such acts.
  4. Proper Bookkeeping and Appropriate Accounting Procedure
    In order to prevent illegal acts such as off-book transactions, fictitious transactions and bribery, the Sanwa group constructs its financial statements on all transactions and disposals of assets basing on appropriate accounting procedures and bookkeeping.
  5. General Recognition of the Prohibition of Bribery and Cooperation in Investigation
    ・The Sanwa Group ensures a general recognition of the prohibition of bribery in the group and conducts regular audit to thoroughly forbid such acts.
    ・In case of having been or having the possibility to be involved in bribery or illegal transaction, one should immediately report to or consult with the General Affairs Department Manager of Sanwa Holdings through their according office organization. If the involvement is confirmed, full cooperation in investigation is compulsory.
  6. Facility Payment
    ・Facility payment is a small amount of payment, not based on related laws and ordinances, made in order to facilitate procedures related to administrative services. Depending on the country or region, request for such payment may occur. The Sanwa Group prohibits any such payment to public officials.
    ・In case of an employee conducted such payment in order to obtain business advantage for the company, the employee, in some cases the company also, may be subject to legal liabilities.

For Chinese version (simplified)
For Chinese version (traditional)

Tax Transparency

The Sanwa Group believes that, as an organization with operations spanning the globe, fulfilling our obligations with an emphasis on tax fairness, respecting the spirit of the law and ensuring tax transparency in the countries and regions in which we operate is one of our most fundamental and important social responsibilities. Based on this understanding, we comply with the following principles on tax matters, and we have not been fined or received any sanction in FY2022 that may significantly impact business. In addition, the Group strives to effectively utilize tax incentives in each country and region that are available for use in the course of standard business operations to ensure an appropriate tax burden. At the same time, we do not take advantage of taxation systems by transferring profits to countries or regions with lighter tax obligations, thereby deviating from the purpose of taxation law.

  1. We pay taxes properly in accordance with tax-related laws and regulations.
  2. We conduct proper tax management to ensure errors do not occur in tax accounting and other related measures.
  3. We respect common international rules on international taxation such as BEPS Action Plan and other guidelines set by the Organization for Economic Co-operation and Development (OECD) and the United Nations and comply with the tax laws of each country.
  4. We submit all relevant data to the tax authorities to establish and maintain transparent and constructive relationships, and to validate the integrity of our books and records.

Governance Structure

The Sanwa Group considers tax risks as one of the most important risks. When tax issues arise, the department in charge of taxation reports to the Board of Directors as necessary.
In addition, we take the appropriate steps in line with the tax system trends in the regions in which we operate, based on cooperation between our department in charge of tax matters, our subsidiaries worldwide and outside specialists such as tax firms. We also provide training and guidance on taxation to employees in order to appropriately fulfill our tax obligations.

Please see the "ESG Data/Third-Party Verification" for detailed information about the payments of corporation tax(Domestic, Overseas) :ESG Data/Third-Party Verification