Compliance

Policy

The Sanwa Group ensures compliance with laws, corporate ethics, internal regulations and rules as an important foundation to garner trust and meet the expectations of society.

Formulation of our Compliance Code of Conduct

In order to maintain the trust of society, the Sanwa Group formulated in October 2005 the Compliance Code of Conduct, which outlines specific conduct that must be adhered to and is based on the Group’s mission, Our Values, Principles of Business, and values, and distributed it to all Group employees in January 2006, together with a case study which provides examples and explanations of actual incidents that occurred in individual departments, as the Compliance Code of Conduct and Case Study Booklet.
The Code of Conduct was reviewed and revised in December 2020, focusing on items such as respect for human rights, ethical behavior, and information security to meet the changing demands of society.

Compliance Code of Conduct

Basic principles and spirit

  • 1.The Sanwa Group must conduct company activities with top priority placed on the safety of the products and services that we provide.
  • 2.The Sanwa Group will not seek profit through actions, which violate the compliance code of conduct.
  • 3.All management personnel and supervisors of the Sanwa Group will take the lead in observing the compliance code of conduct, and will act in such a way as to be a good example for those staff under them.

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

Compliance Chart

Promoting Compliance Awareness in Japan

Training for managers at Group companies in Japan is conducted nationwide to raise compliance awareness and eliminate breaches of laws, regulations and rules. The training aims to foster greater awareness of the need for compliance through lectures on risk, which includes sections on safety obligations, harassment, information security, human rights and anti-corruption, in addition to lectures to bolster knowledge of business-related laws such as the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade, the Construction Business Act, Waste Management and Public Cleansing Act and the Labor Standards Act.
The frequency of the training course was changed from once every three years to once every two years in fiscal 2018 to further instill a compliance-oriented mindset.

Deepening Compliance Awareness at Group Companies Overseas (Asia)

Compliance training at Novoferm (Shanghai)

Compliance Code of Conduct Pledging Ceremony at Shanghai Baosteel-Sanwa Door

In 2017, we conducted compliance training at Shanghai Baosteel-Sanwa Door and Novoferm (Shanghai). A total of 85 Japanese expatriate and local senior management personnel took part in the sessions. We invited an attorney well versed in dealing with issues specific to China to give a lecture about the legal aspects and practical measures for handling corruption among civil servants, which is a problem in China. The attorney also presented case studies involving foreign-affiliated companies. In addition, the General Manager of the CSR Promotion Department provided an explanation of the concepts of the Compliance Code of Conduct that the Sanwa Group is promoting in Japan with the goal of contributing to a unified awareness of compliance throughout the Group.

Each subsidiary in Asia continues to conduct employee compliance awareness activities such as reading the Compliance Code of Conduct and Case Study Booklet, holding study sessions, uploading the documents to the intranet, and collecting signatures on pledge forms.

In addition, the Audit Department of Sanwa Holdings conducts internal audits of not only domestic Group companies, but also of overseas Group companies. In FY2019, we conducted audits at Shanghai Baosteel- Sanwa Door and Novoferm (Shanghai) related to accounting, installation, construction, labor practices, internal controls, governance, risk management, and other areas in accordance with local regulations.

Introduction of Internal Whistleblower System at Companies in Asia

Card in the Thai language announcing the introduction of the internal whistleblower system

Starting in July 2019, we have introduced whistleblower systems (corporate ethics hotlines) at six companies in China and other areas of Asia. We have developed a system that employees can understand through the use of the native languages (or equivalents) in each region, displaying posters and distributing cards to employees in English, Chinese (simplified, traditional), Vietnamese, and Thai. We have also appropriately publicized the system and have worked to increase trust by keeping reported information strictly secret and prohibiting the adverse treatment of system users.

Overview of Initiatives

Japan

Compliance poster
  • Distribute Compliance Code of Conduct booklet to all employees
  • In fiscal 2017, increased compliance training for managers from once every three years to once every two years
  • Designate November as Compliance Month and implement various initiatives annually to promote employee awareness of compliance
  • Put up a compliance poster in offices and Factories (Group Companies in Japan)
  • Establish a Corporate Ethics Hotline as an internal whistleblower system, enlisting the services of an outside provider
  • Conducted an employee awareness survey in Japan

North America (ODC)

e-learning system at ODC
e-learning system at ODC
  • Compliance training is conducted annually using My Learn, an e-learning system on the Company’s intranet, and all employees take part. The training includes advice on how to avoid harassment in the workplace, business ethics, and how to avoid and quickly detect violence and bullyingant in the workplace.
  • Established both inner-company and independent anonymous whistleblower systems.

Europe NF Group

Internal whistleblower system at the NF Group
Internal whistleblower system at the NF Group
  • Distribute compliance handbook and collect signatures on the pledge form. Conduct training at each company
  • Establish internal anonymous whistleblower system with the NF group CFO being responsible for
  • Install internal bulletin board on internet for compliance handbook and compliance code of conduct, anti-bribery guideline, anti-trust law guideline
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