Compliance

After underlining compliance as our “top priority for business activities”, we fixed our Nippon Kayaku Group Charter of Conduct and Code of Conduct in the year 2000. We revised the contents in 2011 in line with ISO26000 (Guidance Regulations on the Social Responsibilities of Organizations), and again in 2020 when resolving to voluntarily implement measures towards achieving a sustainable society.

Pharmaceutical companies are demanded to constantly ensure high ethical standards and transparency; build relationships of mutual trust with external stakeholders such as medical, dental and pharmaceutical researchers, medical professionals, wholesalers and patient groups; and work towards optimal and ethical medical care from the patient’s standpoint.
As the standard by which to judge whether our actions align with the aims of the JPMA Code, we have fixed a Nippon Kayaku Code of Practice. Thus are we further clarifying the corporate ethics and compliance awareness campaigns which form the bedrock of our business activities, and promoting respect for those key areas in the conduct of business and from a high ethical standpoint.

In line with our basic policy on internal system structure, the Nippon Kayaku Group has set up an Audit Division, under the direct supervision of the President, to contribute towards strengthened corporate governance in the form of anti-corruption stances, prevention of unfair or erroneous practices, business operational reform, and asset safeguarding. Based on the annual audit plan approved by the Sustainable Management Meeting does this Audit Division internally audit every division and section of both domestic and overseas Group companies once every three years. Such internal audits involve assessing the systems for business, operational, financial and legal management, as well as observation of ethical standards and anti-corruption measures. Audit results are not only promptly shared with the President, auditors, and the Audit & Supervisory Board, but periodically reported to the Board of Directors via our internal database.

With the installation of its Internal Whistleblowing System and the setting up of its Compliance Hotline, Nippon Kayaku is working on prevention and early detection of unfair practices, and relevant corrective measures.
Our Compliance Hotline is available to all domestic Nippon Kayaku Group executives, employees (including contracted and part-time employees), temp staff and retired employees (up to a year after they have left). Overseas Group companies, meanwhile, have set up their own internal whistleblowing systems.
Whistleblowing reports may pertain to malpractice, such as law violations, unjust practices, violations of internal regulations such as the Group Charter of Conduct and Code of Conduct, and actions contravening corporate morals. They may also pertain to human rights violations, harassment, bribery, unfair trading, and more generic corrupt practices. When it comes to malpractice, or the risk of malpractice occurring in Nippon Kayaku Business, we are ready to accept a whistleblowing report or consultation at any time.
Our Compliance Hotline, meanwhile, runs to both our Ethics Committee Office (the Internal Control Management Division’s Compliance Manager) and an external law firm, and allows whistleblowers to choose anonymity or otherwise when reporting or consulting. Reports may be made via telephone, email, document or interview, with email and document submissions accepted 24/7.
Any report or consultation accepted by the Compliance Hotline reception desk will be examined by the Ethics Committee Office, which will then decide on whether to investigate the facts. If, during any investigation, evidence of malpractice becomes clear, the Ethics Committee Office will promptly devise measures for corrective response and recurrence prevention, and subsequently notify the whistleblower of the investigation results.
Our Internal Whistleblowing System guarantees both confidentiality and anonymity, and our Regulations on Handling Internal Whistleblowing Reports specifically state that the whistleblower shall not receive any kind of negative treatment as a consequence of reporting or consulting.
We are raising awareness of our whistleblowing system and Compliance Hotline through group sessions, E-learning, internal portal site announcements, workplace posters, and the distribution of portable cards.

The Nippon Kayaku Group has set up a Compliance Hotline for Suppliers for matters related to law violations. We ask that suppliers confirm Points 1 to 5 below before reporting or consulting via Point Number 6.

1. Available to
   Executives and employees who, in the course of business, are involved in trading with domestic Nippon Kayaku Group companies
2. Focusing on
   Law violations or unethical acts committed by executives and staff of domestic Nippon Kayaku Group companies, or the discovery of readiness to commit such acts
3. Reports and consultations accepted by
   The Ethics Committee Office (Internal Control Management Division), Nippon Kayaku Co., Ltd.
4. Requests regarding reports and consultations
   All whistleblowers should state their name, workplace and department. Whistleblowers unable to give their name can make reports and consultation requests anonymously, but this may impede the establishment of facts and the wider investigation, as well as render it impossible to report back on investigation results and recurrence prevention measures taken.
5. Protection of whistleblowers and consultation-seekers
   All users of our Compliance Hotline for Suppliers will have their personal information strictly handled in line with our Policy for Protection of Personal Information. Such information will only be used as necessary in the conduct of the investigation. Furthermore, whistleblowers will not receive any blowback for the act of having made a report or requested a consultation.
6. To contact us
   Reports and consultation requests should be made to the Compliance Hotline for Suppliers.

The Nippon Kayaku Group conducts annual e-learning courses on its Charter of Conduct and Code of Conduct for all directors, employees (including contract and part-time employees) and temp staff. The program takes place every year as part of compliance training, and is based on the latest situations and case studies pertaining to the Charter of Conduct and Code of Conduct, and related themes, such as anti-bribery and anti-corruption, basic human rights, harassment, and how to use our internal whistleblowing system. We also use regular meetings at each workplace as opportunities to deliver case-study-based training and form study groups.
We also set up harassment prevention training for every executive and employee on an annual basis. The contents are the same for managers and non-managers alike, and involve sharing awareness of harassment definitions, case studies, preventative measures and responses to actual situations, as part of broader initiatives to increase awareness and prevent before the event.
In addition, to boost thorough compliance across the entire group, we provide compliance training for all group company directors to promote the acquisition of necessary knowledge from a managerial perspective.
So that training opportunities and programs can be provided to every employee, we mainly rely on E-learning methods and large group sessions at Group companies.

Our Compliance Consciousness Survey has been conducted in conjunction with a contracted consultancy firm since FY2015. From the aggregated results and subsequent analysis do we extract the key compliance promotion issues for each company workplace and provide the relevant feedback, including improvement suggestions. That feedback is then referenced by each workplace when it draws up and fixes its Compliance Action Plan for the following financial year, thereby building PDCAs to improve compliance consciousness.