The corporate activities of the SMM Group are founded upon principles of compliance. Though compliance is usually construed as applying to only laws and regulations, the SMM Group goes further, viewing compliance as the fulfillment of social and moral duties as a member of society through sound corporate activities. In 2000, the year after the JCO criticality accident(*1) of September 1999, the SMM Group formulated a Corporate Reform Plan and embarked on a new beginning with three initial priorities:
1. Reconfirmation and Thorough Execution of the Corporate Philosophy;
2. Reinforcement of Corporate Organization;
3. Reform of Corporate Culture.
Based on the above, in 2004, we established the SMM Group Corporate Philosophy and the SMM Group Code of Conduct to be applied throughout the SMM Group. The Code of Conduct(*2) was revised in 2008 in line with the full-scale launch of our CSR activities and revised again in 2015 for responding to globalization and strengthening of CSR activities to further advance initiatives steadily put in place based on our long-term vision articulated in the 2012 3-Year Business Plan.
We put compliance at the top of 17 items in the Code of Conduct, and set forth, not only as abidance by laws and regulations, but also by social norms, the following:
Compliance management is performed according to our basic compliance regulations. We have established the Compliance Working Group under the CSR Committee to promote and improve compliance management. The Compliance Working Group provides and exchanges information, discusses policy and key measures concerning the promotion of compliance to the SMM Group.
In FY2015, the Compliance Working Group convened and confirmed the following.
In FY2015, Taganito HPAL Nickel Corporation (THPAL) was issued with a notice of violation of the Philippine Clean Air Act (PCAA) Enforcement Ordinance by the Environmental Management Bureau (EMB) of the Philippines and fined based on a Presidential decree due to a hydrogen sulfide leak. In addition, Peru’s Ministry of Environment disclosed the name of Sumitomo Metal Mining Peru S.A. for failing to restore exploratory drilling sites within the license deadline. Restoration of sites has already been completed. Aside from these cases, there were no major violations of laws or regulations relating to products and services, including competition laws.
The Compliance Working Group confirmed that key matters related to compliance were made known to employees through a range of various training programs, including the fact that the Sumitomo Business Spirit, SMM Group Corporate Philosophy, and Code of Conduct require ethics-based conduct and decision-making that goes beyond abidance by the laws and regulations.
Also, in order to prevent serious violation of the law from occurring, we instituted the following company regulations, promoting compliance.
In situations where problems or doubts under the SMM Group Code of Conduct occur, and consultation with superiors fails to bring forth an appropriate response, employees are able to use the Speak Up System to directly report the matter to: (i) in-house liaisons which are the general managers of the Legal & General Affairs Department, the Safety & Environmental Control Department, and the Internal Audit Department; or (ii) outside liaisons which are designated attorneys. The source of the information is always kept secret and if, for any reason, the informant is unfairly treated, the person who initiated the unfair treatment will be punished appropriately.
In FY2015, there were 10 cases in which the Speak Up System was used. These comprised: five cases regarding employment management, salaries, and recruitment, three cases regarding the work attitude of supervisors, one case regarding safety management, and one case regarding worksite management. These cases were all handled properly.
The SMM Group has been holding annual “compliance conferences” every year since 2001, which give employees an opportunity to reaffirm their basic knowledge of compliance and learn about the latest legislative changes. After deliberation on the objectives and structure of these conferences, the Group now also implements “compliance seminars” for the senior management of SMM and group companies to ensure the implementation of the Code of Conduct and compliance with related laws and regulations.
In compliance seminars, participants not only acquire knowledge of laws and regulations but also carry out group work on their own initiative to share issues for ensuring compliance as an organization and the ideals for senior management with the primary aim of putting the knowledge acquired through the seminars into practice in their own workplaces.
In addition to seminars, we repeatedly provide guidance on the implementation of the Code of Conduct and compliance with laws and regulations, and CSR awareness in a combined manner through everyday work.
|Type of seminar||Target||Participants|
|Compliance education||Compliance seminar
|Newly-appointed general managers of divisions and group company officers, general managers of head office divisions, heads of branches and general managers of district divisions and plants, and managers of general affairs sections||41|
|General managers of business divisions and administration departments, general managers of head office divisions, and heads of branches and general managers of district divisions, and presidents of subsidiaries in Japan, etc.||66|
|Special seminar for group company presidents||Group company presidents (35)||79|
|Seminar for group company officers||Group company officers (44)|
|Group seminar for new employees||New management track employees and normal track employees in the Head Office area||33|
|Seminar for newly promoted S-class employees||Employees newly promoted to S-class||30|
|Seminar for newly promoted E-class employees||Employees newly promoted to E-class||57|
|Seminar for newly promoted section managers||Employees newly promoted to section manager||19|
|Secondary training for mid-career employees||New mid-career employees||2|
|JCO Study Center training||All SMM Group employees||713|
|Compliance seminar for section managers/senior staff at sites||Personnel at section manager/senior staff level providing guidance on compliance at each division/group company||33|
All officers (including executive officers) and staff (including fixed-term and temporary employees) shall, in accordance with the corporate philosophy of the SMM Group, comply with the following Code of Conduct. Officers in particular shall, in reflection of their position and responsibilities, exercise strict self-discipline, set an example in carrying out the Code, and educate employees to honor and strictly obey the Code in full.