Compliance Initiatives
We declare the corporat philosophy below.
“We agressively act to grow our business by mobilizing all available intelligence and energy with prime importance on credibility and integrity.” and
Our aim is not only to develop creative technologies and provide useful products, thereby contributing to the growth of society and the company, but having officers and personnel engage in a trustworthy and sincere manner, thereby earning the trust of society as we pursue our business activities.
Obtaining the trust of society requires that we strictly comply with laws, statutes, and standards of ethics as a matter of course. In that sense, we consider compliance to be one of the most critical spokes of our business.
Our business would never succeed without the trust of society. Pursuit of profits at all costs, even if it means violating the law or codes of ethics, is not tolerated here. In addition, our clients and stakeholders oversee our firm’s compliance activities and act as members of society to appraise our conduct in the world at large. The trust in our firm, the continuation of our business, and our ability to succeed as a going concern are dictated by this external appraisal.
Strict compliance is a deep part of our company’s culture, and we wish to grow our company globally based on that solid foundation, working hand-in-hand with company officers and employees.
It is our strong wish that all officers and personnel of the company commit to compliance.
April 2022
President: NISHIMOTO Ray
Koei Chemical Charter for Business Conduct
We, all of the directors, officers and employees of Koei Chemical Company, Limited, hereby declare that we fully understand the Corporate Philosophy and conduct business in accordance with the Charter for Business Conduct described below:
“We will strictly comply with domestic and international laws, regulations, and administrative orders.”
“We will carry out our activities in compliance with our corporate rules.”
“We will respect norms and ethics established in our society.”
Summary of Compliance System
1．Compliance System and Organization
Following the standards outlined in the Koei Chemical charter for business conduct, we have created a set of compliance regulations and employ the following compliance structure and system in order to effectively achieve compliance-oriented management.
- Creation of compliance manual (Koei Chemical charter for business conduct) The compliance manual stipulates the rules that company officers, employees, seconded employees, commissioned employees, part-time employees, and other personnel engaged in company business and under the management and supervision of the company (“officers and personnel”) must follow in order to strictly comply with applicable laws, statutes, company regulations, and standards of ethics in society.
It contains twenty-six key areas describing codes of conduct that standards officers and personnel must follow, including codes of ethics not explicitly codified. - Creation and operation of compliance committee
We have created a compliance committee that is tasked with implementing compliance-oriented business, and it retains the rights to conduct investigations and audits. - Creation and operation of Speak-up system
Where there is a compliance violation or the risk of the same, the incident is reported up the chain of command to a supervisor and measures taken to address it, or the Speak-up system, a whistleblower hotline, is used to bring the issue to the attention of the compliance committee.
2．Compliance Committee
1. Composition of Committee
The compliance committee comprises the following members. Every March and September, the committee chair convenes the committee and can also convene said committee on an ad-hoc basis.
2. Privileges and Functions
The compliance committee retains the following functions in order to maintain, improve, and enhance the company compliance system and structure.
(1) Making investigations and audits into compliance at our firm and affiliated firms and, as needed, rendering advice on improvement of the same.
(2) Where information is obtained about a compliance violation or the risk of the same, including through the Speak-up system, an investigation is launched immediately and both measures to address the issue and prevents its recurrence are created, and the departments and officers to whom it applies advised accordingly.
(3) In order to ensure thorough compliance, necessary training and advocacy measures within each company department are employed.
Investigations by the compliance committee include but are not limited in their scope to all documents containing information pertaining to work, all communications media (including but not limited to contents of e-mail, and Internet usage logs), contents of media on electronic devices, and any and all other equipment within the workplace.
3．Officer and Personnel Compliance Duties
Each and every officer and employee is solely responsible for implementing compliance. Officers and personnel have the following duties.
(1)Ensuring proper compliance
Officers and personnel must understand the compliance manual (Koei Chemical charter for business conduct), company regulations, domestic and international laws and statutes on business, and codes of ethics and put compliance personally into practice.
(2)Cooperating with investigations and audits by compliance committee
Officers and personnel must cooperate and comply with investigations and audits launched by the compliance committee.
(3)Thorough compliance through measures taken by compliance officer
Executive directors, section directors, department directors, and other managerial personnel overseeing production line work are installed as compliance officers for their respective division and/or workplace. In addition to the above duties of officers and personnel, compliance officers have the following duties.
- Creation and operation of a compliance structure within each workplace
Compliance officers must establish and implement concrete measures to prevent compliance risks to which their department may be subject to from occurring. - Reporting compliance violations or risks of the same, and rapidly responding
Where a compliance violation or the risk of the same is found, the compliance committee must be immediately notified in writing and plans for the resolution and prevention of future recurrence of the issue immediately crafted and employed. - Submission of compliance oath
As a rule, on a date stipulated elsewhere, once a year, an oath on compliance must be submitted per the format stipulated by the compliance committee.
4．Speak-up System
1. Compliance Violations must not be Ignored
Where a company officer or personnel member discovers a compliance violation or risk of the same, irrespective of whether the incident occurs in the department to which the member is assigned, the member must report the incident to the company.
When a violation or the risk of the same is discovered, there are two methods of reporting it.
- Reporting of incident through regular chain of command
- Reporting to the Speak-up hotline
2. The Speak-up Hotline Offers Two Hotlines to Contact
(1)Compliance committee hotlineThe contents of reports notified to the hotline will be immediately sent to the compliance committee chair and permanent audit members. The committee chair or permanent audit members decide whether to hold an immediate investigation and, having ascertained the facts, where the report matches the facts and the incident is a compliance violation, the committee chair convenes the committee and a resolution is made on suitable measures to take.
(2)Outside counsel hotline
Informants can also notify the external counsel specified by our compliance committee. The outside counsel acts as a point of contact for reports and is limited in its capacity to communicating reports to the company and reporting the results of compliance committee investigations and measures taken to the informant, and does not act as a negotiating or mediating party between the informant and company, nor does it personally engage in investigations.
The contents of reports will be immediately sent to the compliance committee chair and permanent audit members. Per directions or request from the committee chair or permanent audit members, an immediate investigation is made and, having ascertained the facts, where the report matches the facts and the incident is a compliance violation, appropriate measures to take are decided on and implemented.
3. Please provide as much detail as possible
The compliance committee requires sufficient information from the informant in order to conduct a proper survey. To that end, you will find some boilerplate templates prepared that contain a series of required fields.
4. Reports can be made both by name or anonymously
Given the need to respond to incidents in an expedient and efficient fashion, as a rule, whistleblower names are used, but the report can be made anonymously if needed. For reports to the outside counsel, where requested by the informant, the report can be made by name to the outside counsel and anonymously to the compliance committee.
5. The privacy of the whistleblower is respected
The compliance committee exercises the utmost care with respect to the privacy of whistleblowers and, in the event of a subsequent investigation, keeps those details private to only those directly involved in said investigation. For anonymous informants, an investigation to identify the party is not launched.
6. The whistleblower will not be subject to penalties
Where the whistleblower is an officer or personnel member of the company, the whistleblower will not be dismissed, transferred, subject to discrimination, or any other disadvantage on the grounds of having made the report. Where the whistleblower is an officer or personnel member of a trade partner, the company shall not cause that trade partner to experience disadvantageous trade terms on the basis of said report. Where the informant is an officer or personnel member of an affiliated company, instructions will be given by our company to the affiliated company such that the informant is not placed at a disadvantage. However, for reports that are intended to deceive others, including but not limited to intentionally conveying false information, or where the report is intended to act as a threat, extortion, or illegal act, the above may not apply. Where the whistleblower is also engaged in activities that are in violation of compliance, making a report does not constitute exemption from disciplinary action for violation of the law.
5．Compliance System for Affiliated Companies
We consider it critical that not only our company, but the entire Koei Chemical group of companies, pursue compliance-oriented management. Our affliated companies have also employed a compliance system equivalent to that at Koei Chemical.
6．Compliance
We require all officers and personnel to strictly comply with the terms below, and we distribute workplace manuals to all officers and personnel that, alongside company-internal regulations, detail the major laws and statutes they are required to comply with.
Employee Duties
1．Compliance with Industry Laws
When carrying out business activities, officers and personnel shall confirm the applicable industry laws, obtain authorization where needed, and properly understand the details therein in order to comply with laws and statutes.
2．Non-engagement with Anti-social Forces
Officers and personnel shall take a resolute stance against anti-social forces and organizations and not engage with them in any way.
3．Environmental Conservation
Officers and personnel shall comply with environmental regulations and make efforts to work with stakeholders to conserve the environment, prevent pollution, and decrease other environmental risks.
4．Safety and Disaster Prevention
Officers and personnel shall properly manufacture, store, sell, and transport potentially hazardous substances and take measures to prevent accidents; in the event that an accident should occur, they shall take measures to prevent its spreading and ensure safety. For facilities handling substances not deemed to have potential hazards, such as air and water vapor, said facilities shall be used per their exact specifications and not in any other ways.
5．Compliance with Import/Export Laws
Officers and personnel shall strictly comply with international laws, statutes, and regulations on trade and carry out appropriate import and export procedures.
6．Export Control
Officers and personnel shall strictly comply with laws and statutes on the manufacture and use of nuclear weapons, biological and chemical weapons of mass destruction, and standard weapons, and laws and statutes on the export of materials and technology related to the same, and fulfill responsibilities to maintaining international peace and safety.
7．Handling of Political Contributions
Where using the Koei Chemical name to give contributions to political parties or organizations, officers and personnel shall first obtain proper internal approval.
8. Compliance with Domestic and International Laws Regulating Exchange of Gifts
Officers and personnel shall not engage in exchange of gifts, or actions equivalent to exchange of gifts, to domestic and foreign public officials.
Relationship with Clients, Suppliers and Competitors
9. Product Safety
Officers and personnel shall ensure safety measures to reduce the threat to health of people, including but not limited to users of our products, and the environment from all chemical substances associated with the materials, intermediates, and products that we handle.
10. Prohibition on Collusion with Clients and Suppliers
Officers and personnel shall not engage in excess entertainment (provision of food and drink) and exchange of gifts (mid-year, year-end, parting gifts, et cetera) of clients, trading partners, and other third parties. Officers and personnel shall not receive excess entertainment or gifts from trading partners.
11. Compliance with Antitrust Laws and Related Regulations
Officers and personnel shall strictly comply with the Antimonopoly Act, Act against Delay in Payment of Subcontract Proceeds, and the antitrust acts of other nations, and not engage in private monopoly, unauthorized trade restrictions (cartels), or unauthorized trading methods.
12．Respecting the Intellectual Property Rights of Other Firms and Securing the Intellectual Property Rights of One’s Own Firm
Officers and personnel shall not infringe on the intellectual property rights of third parties and/or other companies. They shall secure the intellectual property rights of our firm as needed.
13. Prohibition on Unfair Competition
Officers and personnel shall not engage in unauthorized use of trade secrets of other firms, or engage in sales activity that would discredit the reputation of other firms. Officers and personnel shall not engage in sales activities that intermingle company products and sales with those of other companies, or cause trade partners to misinterpret the quality or origins of the product, including but not limited to unauthorized use of products and labels of other parties and manufacture and sale of counterfeit products.
Relationship with Shareholders and Investors
14. Disclosure of Management Data
Disclosure of corporate data like accounting details and activities shall follow the relevant laws and statutes and be done in an accurate and timely fashion.
15. Prohibition on Insider Trading
Officers and personnel shall not purchase or sell stocks or securities based on access to undisclosed internal information, or provide that information to third parties, including one’s family.
Creating a Collegial Workplace
16. Respect for Human Rights
Officers and personnel shall respect human rights and not discriminate against others on the basis of race, creed, religion, nationality, age, sex, physical or mental disability, or any other factors.
17. Compliance with Labor Laws
Officers and personnel shall strictly comply with all laws and statutes on hiring, including but not limited to the Labor Standards Act.
18. Compliance with Employment Regulations
Officers and personnel shall follow all personnel and labor regulations, including the employee work regulations.
19. Safety and Sanitation of Workplace
Officers and personnel shall maintain safety of the workplace and engage in safe conduct around a principle of placing safety above all else. Officers and personnel shall take sufficient care in the management of mental and physical health.
20. Ban on Political, Religious and Other Solicitation
Officers and personnel shall not force, or solicit for, participation in and/or support of specific political parties, religious groups, or other organizations that are based on individual beliefs or preferences.
Protection of Company Assets
21. Management of Company Data
Officers and personnel shall not collect and/or use confidential information on company products, such as expertise and knowledge, beyond the extent needed for one’s work. Officers and personnel shall take all necessary measures in the management of said information to prevent its leak to third parties and/or loss. The same applies to the confidential of other companies in order to prevent its inadvertent use.
22. Management of Personal Information
Officers and personnel shall not collect and/or use the personal information of employees, clients, employees of other affiliated firms, et cetera beyond the scope required for business. Officers and personnel shall take all necessary measures in the management of said information to prevent its leak to third parties and/or loss.
23. Proper Management of Company Assets
Officers and personnel shall keep appropriate logs of company assets, irrespective of whether the assets are tangible or intangible, and these logs shall be used and maintained as necessary.
24. Prohibition on Unauthorized Acquisition of Company Property
Officers and personnel shall not obtain or transfer company assets (whether tangible or intangible) without authorization.
25. Proper Accounting
Accounting shall follow generally accepted accounting standards.
26. Proper Keeping of Transaction Records
Officers and personnel shall keep accurate logs of corporate activity and maintain them accordingly.
27. Prohibition on Competition and Conflicts of Interest
Officers and personnel shall not use their position or information obtained through the course of their work to compete with the company’s business for the benefit of oneself or third parties.
Officers and personnel shall not use their position or information obtained through the course of their work to engage in activities or assume a position that would go against the interests of the company.
7.Whistleblower Hotline and Forms
Contact 1. Compliance Committee
1. General
| TEL | 080-1509-7251 |
| ｓｐｅａｋｕｐ＿ｓｏｕｇｏｕ＠ｋｏｅｉｃｈｅｍ．ｃｏ．ｊｐ (please replace double-byte charcters to one-byte characters) |
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| Documents to | 1-8 Nihonbashikoamicho, Chuo-ku, Tokyo 103-0016 Koei Chemical Speak-up hotline (General) |
| FAX | +81(3)-6837-9307 |
2. Detail
(1) Accounting fraud and Falsification
| TEL | 080-9204-9346 |
| ｓｐｅａｋｕｐ＿ｋａｎｓａ＠ｋｏｅｉｃｈｅｍ．ｃｏ．ｊｐ (please replace double-byte charcters to one-byte characters) |
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| Documents to | 25 Kitasode, Sodegaura, Chiba 299-0266 Koei Chemical Speak-up hotline (Internal Audit) |
| FAX | +81(438)-60-9671 |
(2) Harassment
| TEL | 080-9204-9351 |
| ｓｐｅａｋｕｐ＿ｈａｒａｓｓｍｅｎｔ＠ｋｏｅｉｃｈｅｍ．ｃｏ．ｊｐ (please replace double-byte charcters to one-byte characters) |
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| Documents to | 25 Kitasode, Sodegaura, Chiba 299-0266 Koei Chemical Speak-up hotline (Harassment) |
| FAX | +81(438)-63-5546 |
(3) Safety, Environment and Quality
| TEL | 080-9204-9353 |
| ｓｐｅａｋｕｐ＿ｒｃ＠ｋｏｅｉｃｈｅｍ．ｃｏ．ｊｐ (please replace double-byte charcters to one-byte characters) |
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| Documents to | 25 Kitasode, Sodegaura, Chiba 299-0266 Koei Chemical Speak-up hotline (RC) |
| FAX | +81(438)-63-2297 |
Contact 2. Outside Counsel (Attorney at Law)
Mr. HORIUCHI Yasunori (affiliated with Seiwa Law Office)
| TEL | +81(6)-4706-7727 |
| FAX | +81(6)-4706-7738 |
Files can also be obtained from the links below.
Training and Support of Next-generation and Promotion of Women in the Workplace
We have created this action plan in order to enable company personnel to achieve both childraising and a career, and create a workplace in which all personnel feel comfortable working act and in which they can maximize their potential.
These plans can also be obtained from the links below.
Our plans for promotion of women in the workplace can be obtained from the links below.
Plan for promotion of women in the workplace (PDF in Japanese)
Koei Chemical Basic Policy on Procurement
Koei Chemical employs the following policy in its procurement activities.
1. Fair and Equitable Trading
We continuously seek to create new business opportunities with new clients, using standards of fair, equitable, and free competition, and pursue transparency in our dealings.
2. Selection of Suitable Suppliers
When selecting suppliers, we comprehensively assess the stability of the company, quality and price of products, and development of technology and considerations towards the environment, safety, and health in order to make a reasonable determination on the best suppliers to work with.
3. Mutual Growth
Through constructive relationships with our trading partners, we aim to pursue mutual understanding and growth.
4. Compliance with Laws and Confidentiality
In addition to strictly observing all applicable laws and statutes, company-internal regulations, and their spirit, we take every measure to prevent the unauthorized use and/or leak of confidential information pertaining to our company and trading partners.
