Compliance

• Basic Policy
• Promotion System
• Reinforcing Legal Compliance and In-house Training
• Internal Reporting and Establishment of Consultation Hotlines
• Respect for Human Rights

Basic Policy

Viewing compliance as an important management issue, we implement various initiatives to ensure compliance among all directors and employees not only with all applicable laws and regulations, but also with business and social ethics. We aim to improve our compliance activities by thoroughly implementing the ESG Charter and the Code of Ethical Conduct, which serve as the guidelines for each individual’s behavior, enabling us to build relationships of trust with our stakeholders.

Promotion System

The Compliance Subcommittee in the ESG Committee is responsible for ensuring corporate ethics and compliance throughout the company while promoting and overseeing activities such as checking employees’ understanding and observance and providing consultation hotlines.

Diagram of Promotion System (through Fiscal 2021)

We reorganized our ESG-related organization with the establishment of the Engine of Sustainability Management on April 1, 2022. It is tasked with overseeing and enhancing ESG management.
Established under the Engine of Sustainability Management, the Compliance Committee disseminates corporate ethics and compliance to ensure understanding and observance throughout the Kaneka Group.

Diagram of Promotion System (as of April 1, 2022)

Reinforcing Legal Compliance and In-house Training

The Kaneka Group carries out business activities globally and as various rules are strengthened around the world, it faces a need for even greater legal compliance.
The “Ethical Code of Conduct” and “Compliance Guidebook” that all of our directors and employees should follow are posted on the company’s intranet. We strive to conduct our business activities in a fair, appropriate, and transparent manner.
There were no serious violations of laws, regulations, or rules in fiscal 2021. We conducted ESG evaluation audits at all Kaneka business divisions, 28 Group companies in Japan, and 20 Group companies overseas in the area of competition laws like the Antimonopoly Act in Japan. Executives of Kaneka and Group companies in Japan involved in sales, purchasing, and business development are required to undergo antitrust law compliance training and submit a written oath. At Group companies in Japan, we confirmed the status of issues related to equal pay for equal work and revisions to the Act on Stabilization of Employment of Elderly Persons.
Improving compliance is essential for our business activities since earning the trust of our stakeholders is vital. We will continue to conduct various training programs to strengthen legal compliance and raise awareness.

Excerpts from the Compliance Guidebook

Ⅰ Relationship with Society

1. Environmental Preservation and Protection
2. Compliance with Laws and Regulations
3. Compliance with Export Controls
4. ContribⅠutions and Political Donations
5. Determined Response to Antisocial Elements
6. Timely Disclosure
7. No Insider Trading
8. Proper Accounting and Tax procedures

Ⅱ Relationship with Customers, Business Partners, and Competitors

1. Product Safety
2. Compliance with Antitrust Laws
3. Fair Dealing with Contractors
4. Trade Secret
5. Appropriate Advertise and Publicity
6. Entertainment and Gift

Ⅲ Relationship with Employees

1. Respecting Human rights and prohibiting discrimination
2. No Sexual Harassment
3. Protection of Privacy
4. Safety and Hygiene at Workplace
5. Strict Adherence to Labor-related Laws

Ⅳ Company Properties

1. Trade Secrets
2. Company’s Properties
3. Intellectual Properties
4. Use of Information Systems

Internal Reporting and Establishment of Consultation Hotlines

To prevent compliance violations and ensure early detection and prevention, we have established internal reporting and consultation services within the Company and at outside law firms.
In fiscal 2021, there were five cases of reporting and consultation concerning violation of internal rules, harassment, work content and work environment. Fact-finding investigations and hearings were conducted, and the cases were handled in accordance with internal rules. The details of the cases are reported regularly to the Compliance Subcommittee. In addition, we have established rules on whistleblowing and employee employment regulations to ensure that whistleblowers and consultants are not subject to any discrimination.

Respect for Human Rights

Human rights are the rights that anyone can feel, the right to live like a human being, which each and every one of us is born with. Since its foundation, Kaneka has practiced respect for humanity in its management. We have a fine tradition of maintaining a culture and climate that tries to make the most of the good qualities of each individual. We see respect for human rights as a fundamental principle that should be upheld by the Company and each of its employees. Throughout our business activities, we strive to raise awareness of respect for individuality and human rights.
To maintain a workplace environment where all employees feel healthy and fulfilled in their work and where there is no harassment, we will deepen awareness and understanding among employees and make the workplace environment a more comfortable place for them to work.

Human Rights/Compliance Education