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.

Initiatives

  • Training on cease and desist measures in the Kinki region (187 participants in fiscal 2019)
    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. Going forward, we plan to provide the training nationwide.
  • Formulated guidelines and regulations on contact with industry competitors in February 2011 (Revised in November 2014)

Anti-corruption

Policy

The Sanwa Group comprehensively covers the topic of corruption in its Compliance Code of Conduct, 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 whistleblowing system allows for anonymous reporting and guarantees that confidential information will be handled confidentially, in order for the early detection of any form of corruption, violations of the Compliance Code of Conduct, and suspicious behavior.

System

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 2019.

Initiatives

All employees are informed of our anti-corruption policy through the Compliance Code of Conduct. In addition, we provide compliance training for managers at domestic Group companies every other year.

In addition, we have identified China and Vietnam 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)

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 fiscal 2019 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.

System

The Sanwa Group has positioned taxation risk as a critical risk to be addressed and the Board of Directors is responsible for overseeing such a risk.
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"Latest ESG Data"for detailed information about the payments of corporation tax(Domestic, Overseas) :Latest ESG Data

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