SUMITOMO CHEMICAL Creative Hybrid Chemistry
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Compliance System
The Company's compliance system and its organization
Our Company aims to effectively implement corporate management practices that place importance on compliance, based on the spirit of the "Sumitomo Chemical Charter for Business Conduct." To this end, we established on July 1, 2003 the compliance system and related organization as described below.

Sumitomo Chemical Business Conduct Manual
All members of the Board of Directors and all employees, loaned employees, temporary employees, and other personnel who are engaged in business operations for or on behalf of the Company under its management and supervision (referred to hereafter as"directors and employees") must abide by laws, regulations and business ethics and promote compliance-based management. The Manual defines various rules to be observed by directors and employees.

Compliance Committee
The Compliance Committee supervises and supports the effective implementation of compliance-based corporate management. The Compliance Committee has the authority to undertake investigations and supervision that are necessary to ensure such compliance-based management.

Speak Up System
If an act of noncompliance occurs or there is the possibility of noncompliance, and the problem for some reason cannot be, or is not likely to be, resolved immediately through the normal process of reporting to a superior, an employee may report through the "Speak Up System." We expect that the Speak Up System will not only be effective in preventing illegal or unfair activity, but also capable of performing a self-regulating function because if an illegal or unfair acts can be immediately identified and rectified through the System.
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Compliance Committee across-company
The Compliance Committee is a cross-company investigative and supervisory body devoted to maintaining standards of corporate ethics. The Compliance Committee consists of a Chairman and Vice Chairman, nominated by the Company's President, and several members, as well as the office of the secretariat. The aims of the Compliance Committee are:

1) To assist in the maintenance, improvement and promotion of compliance-based management by the Company and its domestic and overseas group companies;
2) To investigate and audit the compliance situation at our Company and its domestic and overseas group members, and advise on improvement of the situation if necessary;
3) To immediately investigate a situation of noncompliance when a report is received under the Speak Up System, prepare plans for rectifying the situation and preventing its recurrence, submit the plans to the President, and upon approval, advise the relevant departments of necessary countermeasures;
4) To implement necessary measures, including education and awareness-raising activities, in order to expand the understanding of compliance-based management thoroughout the organization.
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Compliance by directors and employees
Each and every director and employee is obligated to act in accord with compliance requirements, and must cooperate in investigations and audits made by the Compliance Committee.
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Speak Up System
1) You are obligated to report to your superior or the Speak Up Desk if you come to know that an infringement of any of the laws, regulations, company rules or ethics (referred to hereafter as "noncompliance") has taken place, or is likely to take place, in our Company, whether in the department where you work or in other departments. If an act of noncompliance takes place in your own department, you are basically required to report it to your superior in accordance with the normal reporting process. If a problem cannot be, or is not likely to be, immediately or effectively resolved through the normal reporting process, however, you are urged to report the matter to the Speak Up Desk hotline under the Speak Up System.
2) In addition to directors and employees, their family members or any other persons involved in our business activities, including those working for our Company's group companies or trading partners, may report cases of noncompliance to the Speak Up Desk.
3) To enable the Compliance Committee to conduct an investigation, informants must provide the Committee with sufficient information. When an informant provides information in writing, including by letter, e-mail or fax, the informant is required to use the prescribed written form. The form appears in the "Form and Contacts for Reporting" section of this site. You can download this form via the intranet/internet. Informants are required to use the form and complete all necessary items. If e-mail is used, the proper form with all necessary items completed should be attached to the e-mail message.
4)
As the speak Up Desk, two hotlines---the "Compliance Committee Hotline" and the "External Lawyer Hotline"---have been established as described below. An informant may contact either of these two hotlines. To enable a prompt and effective response, an informant is, in principle, required to report to the hotline indicating his or her name. However, an informant may provide information anonymously. It should be noted, however, that if anonymous information is provided, it may be difficult to fully investigate the case, which may make it impossible to undertake the necessary response, including an appropriate investigation. The contacts for these hotlines are indicated in the section on "Form and Contacts for Reporting".

(1) Compliance Committee Hotline
The information provided to this hotline will be immediately reported to the Compliance Committee Chairman. If instructed by the Chairman, an investigation will be implemented at once to ascertain all the facts. If it is determined that the information is accurate and an act of noncompliance has taken place, the Chairman will convene the Committee to decide on an appropriate response. If the information was provided by an informant giving his or her name, the results of the investigation and the response to the reported situation will be communicated to the informant.
This hotline has two desks, a general desk and individual desks dealing with specific noncompliance subjects. Informants may provide information to either of these two desks.

(2) External Lawyer Hotline
Informants may provide information to the external lawyers designated by the Compliance Committee. Informants are required to provide information to the external lawyer in writing (including by letter, e-mail or fax) using the prescribed form so that the information can be conveyed accurately and without fail to the external lawyer. The contents of the information provided to the external lawyer will be immediately reported to the Chairman of the Compliance Committee . If so desired by the informant, the name of the informant will not be identified in the report made by the external lawyer to the Company. After receiving the report from the external lawyer, an investigation will be conducted, by the instruction of the Chairman, to ascertain the facts of the situation. If it is determined that the information provided is accurate and an act of noncompliance has taken place, the Chairman will convene the Committee to decide on an appropriate response.
The Compliance Committee will inform the external lawyer of the result of the investigation and the Company's response, and the external lawyer will transfer this information to the informant.
As mentioned above, the role of the external lawyer as a reporting hotline is limited to the transfer to our Company of the information provided by an informant, and the transfer to the informant of information concerning an investigation undertaken by our Company. This is because the external lawyer is not authorized to act as an intermediary in negotiations between an informant and our Company, to convey to our Company the demands of an informant relating to his or her personal interests, or to communicate to the informant the reaction from our Company to such demands.

5) The Compliance Committee gives the utmost importance to the protection of informants' privacy, and keeps in confidence the fact of the reporting itself as well as the contents of a report to anybody other than those engaged in the investigation.
6) If an informant is a director or an employee of our Company, our Company will not resort to unfair treatment, such as discharge, transfer or discrimination, on the grounds that the person concerned acted as an informant. If an informant is a director or an employee of a group company, our Company will direct the group company not to treat the informant to his or her disadvantage. If an informant is a director or an employee of one of our Company's trading partners, our Company will not treat the business partner to its disadvantage for the reason that it employs an informant. The foregoing does not apply, however, if an informant intentionally provides false information with the aim of damaging other persons, or if an informant commits an illegal act by threatening or blackmailing. If the informant is himself or herself involved in the case of noncompliance, our Company will not hold the informant immune from the consequences of such noncompliance.
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Compliance System for Sumitomo Chemical's group companies
It is important that not only our Company but also our entire group of companies in Japan and overseas undertake compliance-based management. Therefore, our main group companies will establish and implement compliance systems comparable to that of the parent Company.
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