Governance

Compliance

Basic Stance

GlobalGlobal

Policy

In the pursuit of the smooth operation of its business, the Calsonic Kansei Group recognizes the importance of all employees practicing compliance, based on a strong sense of ethics. The Calsonic Kansei Global Code of Conduct was established in 2003 in order to strengthen the global compliance structure. This serves as a shared code of conduct that defines proper behavior for employees around the world, and it applies to the entire Calsonic Kansei Group.

Compliance Promotion System

GlobalGlobal

System

The Calsonic Kansei Group has established the Compliance Risk Management Committee to promote compliance in each region and at each of our business locations around the world. It has assigned executives and staff members responsible for compliance at each business location, and is working to spread and foster an awareness of compliance.

Global Compliance Structure

Global Compliance Structure

Spreading Awareness of Compliance

Periodical Monitoring

GlobalGlobal

System

The Calsonic Kansei Group periodically monitors the major compliance activities of its regions and business locations around the world under the compliance program consisted of seven elements. The outcomes of this monitoring are reported to the Compliance Risk Management Committee to assist in further improvements of the process.

COMPLIANCE PROGRAM
  1. Standards and procedures
  2. Organizations
  3. Education and training
  4. Monitoring and auditing
  5. Incentive and discipline
  6. Reporting and investigating
  7. Response and prevention (management of compliance risks such as anti-bribery and anti-trust)

Compliance Education and Awareness

GlobalGlobal

System

The Calsonic Kansei Group conducts training on the Code of Conduct every year and collects pledges in order to strengthen awareness about compliance. In fact, 100% of our employees in Japan and overseas signed pledges in Fiscal 2016. As part of our education on the Code of Conduct, we also provide education as necessary on the global risks of anti-trust law and anti-bribery law. For these risks, we have established basic policies and rules – global (group-wide), for our Japanese locations, and for our overseas locations and conducted communication and awareness-raising activities across the entire Calsonic Kansei Group. In Fiscal 2016, in addition to our full participation education program, we also held training for corporate officers on anti-bribery law in Japan, and anti-trust law and anti-bribery law training for the relevant departments in Japan, the Americas, and Europe, in our efforts to keep the relevant people fully aware of these risks. We will also progressively hold this targeted training in Asia, with the aim of reducing the risks on a global basis. We have also developed our CSR Guidelines for Suppliers and asked their cooperation in ensuring anti-bribery and other compliance.

Anti-bribery training for corporate officers in Japan

Internal Whistleblowing System

GlobalGlobal

System

The Calsonic Kansei Group has introduced a Group-wide internal whistleblowing system to ensure that each and every employee understands and implements compliance and is able to confirm whether corporate activities are being conducted properly. We have developed a framework that enables employees to directly communicate opinions, questions, and requests to the company. This is helpful not only in terms of improving operations and the workplace, but also in terms of creating a corporate culture that complies with corporate ethics. This framework also incorporates the concept of whistleblower protection in accordance with the Whistleblower Protection Act that came into effect in April 2006, in accordance with which it operates an external CK Helpline to serve as the contact point in Japan. The CK Helpline accepts reports both online and over the phone and allows employees to make reports using either their actual name or anonymously. An experienced person from a third-party organization receives the reports while protecting the privacy of the whistleblower, and then contacts the related department or organization so that the appropriate response can be taken. In each region and business location around the world, we have also established and run internal whistleblowing systems that are optimized for each company while giving consideration to the culture and laws of each country. In the Americas and Europe, we have established hotlines as external contact points that accept reports 24 hours a day. We will also look into the establishment of an external contact point in Asia going forward. Under our whistleblowing systems, we respond carefully to ensure that whistleblowers do not suffer any disadvantages from the perspective of whistleblower protection. In terms of internal whistleblowing systems, in Fiscal 2016, we established a whistleblowing contact point for suppliers, as well as employees. As with reports from employees, any reports received from suppliers will be dealt with in confidence to protect the privacy of the whistleblowers, to ensure that they are not disadvantaged.

In the event of behavior in a workplace that could be suspected of a human rights violation, the company must be prompt in understanding the situation and taking an appropriate response. The Calsonic Kansei Group believes that respect for human rights and the prevention of human rights violations are important to the employee whistle blowing system’s interview process. Confidentiality is strictly adhered to in the running of the system, including the privacy of the person seeking advice, to ensure that the whistleblower does not suffer any disadvantages.

In fiscal 2016, 312 whistleblowing cases were recorded across the entire Group. All cases were satisfactorily dealt with and improvements made to the system, in consultation with the relevant departments.

Trends in Number of Whistleblowing Cases

2014
234cases

2015
309cases

2016
312cases

Export Control (Security Trade Control)

GlobalGlobal

System

The Calsonic Kansei Group has established the Export Control Committee, led by the CEO, to comply with Export Trade Control Orders and Foreign Exchange Orders under the Foreign Exchange and Foreign Trade Act. This committee also implements appropriate export control of goods, technologies and other matters with the potential to be diverted into weapons and military use. It consists of members of each division involved with exports, and its tasks include control of the export of parts, equipment and measuring instruments, control of the transfer of technologies and engineering diagrams, acquiring information on new laws and regulations, and training of employees. Overseas, personnel responsible for exports at each business location conduct proper management in cooperation with corporate headquarters to comply with the export control regulations of each respective country.

There were no violations of such regulations in Japan or overseas during Fiscal 2016.

Export Control System

Export Control System