Approach

The SMM Group’s corporate activities are based on compliance. We believe in going beyond just complying with laws, regulations, Articles of Incorporation, and our own rules, and working to fulfill the moral and social responsibilities demanded of us as a member of society through corporate activities. We continue to advance various initiatives based on this approach.

Promotion Framework

The president is the person responsible for compliance initiatives and he appoints an executive to take charge of implementation.
Compliance is promoted through management lines at each site and its basic components are (1) executing operations based on compliance with laws and regulations, (2) picking up any issues concerning compliance, and (3) carrying out education and fostering awareness of legal compliance.
Compliance is managed according to our internal basic compliance regulations. We have established the Compliance Working Group (WG) under the CSR Committee to promote and improve that management. The Compliance WG provides and exchanges information, and discusses policy and key measures concerning the promotion of compliance.

Initiatives

Initiatives to Take on Issues and Provide Improvements

In FY2019 we formulated the following Group-Wide Compliance Goal and compliance priorities, and promoted initiatives to reach these in each department.

FY2019 Group-Wide Compliance Goal:

Prevent compliance violations that may seriously damage business.

Compliance priorities:

  1. Communicate to all employees a consistent approach to our compliance and strive to further enhance the ethical mindset of each individual employee.
  2. Foster an organizational culture that emphasizes compliance, especially among business site general managers, and strive to create workplaces that make it easy for employees to report issues.
  3. Identify and thoroughly comply with laws and regulations directly related to the protection of lives and physical safety.

Also, the Compliance WG was convened in FY2019, confirming the following.

  • The results of checking FY2019 compliance status show that there were no serious legal or regulatory violations, including cases of corruption or breaches of the Antimonopoly Act, regarding the environment, products, service, or marketing.
  • Issues revealed through analysis of the results of a compliance themed employee awareness survey implemented in February 2019, and future measures to solve these issues have been shared.
  • The current system for reporting compliance violations has been revised to encourage swift reporting from a crisis management perspective and to enhance measures aimed at preventing the reoccurrence of similar situations, and details of the new system have been shared.
  • Progress is being made toward achieving targets set by each department in accordance with the Group-Wide Compliance Goal and compliance priorities for FY2019.

To address the risk of serious violations of the law in our Group, we have established the following company regulations and are working to prevent legal violations.

  • Regulations on insider trading prevention and information management
  • Regulations on the safeguarding of personal information
  • Export administration regulations
  • Regulations for the prevention of bribery
  • Regulations for observance of competition law, etc.

Compliance Employee Awareness Survey

In February 2019, we implemented a compliance themed employee awareness survey. Analysis of the results of this survey revealed issues that need to be addressed going forward.
In addition to implementing measures that will prevent the occurrence of compliance violations that might have a serious impact on our business, we will also implement measures to create workplaces that can respond appropriately to any compliance issues in terms of organization and in accordance with internal rules.

Compliance with Competition Laws

In April 2019, the SMM Group formulated its Basic Policy for Compliance with Competition Laws and we have established regulations for observance of competition law based on this policy, which indicate the duty of its officers and employees to prevent acts prohibited under those laws through efforts such as refraining from conducting unfair transactions or making a prompt report to their superior or otherwise taking necessary action when they discover potential violations of those laws. Additionally, we have created a Competition Law Compliance Manual that explains the content of the basic policy and regulations in an easy-to-understand manner, with a focus on acts that violate competition laws and points to be aware of when conducting everyday duties.

Hotline (Speak Up System)

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 internal reporting hotline (Speak Up System) to directly report the matter to: (i) in-house liaisons which are the general managers of the Legal Department, the Safety & Environment 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 treated unfairly, the person who initiated the unfair treatment will be punished appropriately.
In FY2019, there were 10 cases brought up through the SMM Group hotline (Speak Up System). Broken down, these were five cases involving harassment, four cases involving human resources and labor management, and one case involving a relationship with a business partner. Each of these consultations was handled appropriately.

Participants of Compliance Education (FY2019)

Type of seminar Target Participants
Compliance seminar for general managers
Compliance seminar for officers
JCO Study Center training
Introductory training for new employees
Seminar for newly promoted employees
(section managers, E-class, S-class)
Officers 48
Employee 552

SMM Group Code of Conduct

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.

1. Compliance: Abidance by Laws and Rules

  • We will comply with foreign and domestic laws and rules, and conform to social norms.
  • We will never under any circumstances commit an infraction of the law or act counter to social norms, even if doing so would seem to be in the company’s interests.

2. Respect for Individuals

  • We will accept diversity and respect the individuality and rights of people.
  • We will never violate human rights, engage in discriminatory conduct, or contribute to such conduct.

3. Assurance of Health and Safety

  • We will give highest priority to ensuring the physical health and safety of all persons affected by our operations.

4. Development of Human Resources

  • We will strive not only for personal self-improvement, but also to nurture successors through systematic training and by providing various opportunities in the course of work.

5. Risk Management

  • We will strive to identify risks, prevent their occurrence, and if risks occur, minimize the effects.

6. Adherence to a Progressive Stance

  • We will approach our jobs with a positive and progressive attitude suitable to the creation of technologies and systems in the vanguard of changing times.

7. Respect for Teamwork, Promotion of Good Communication

  • We will place high value on teamwork, in the form of cooperation both with other organizations and with fellow workers.
  • We will strive to create a cheerful and broadminded corporate atmosphere conducive to the smooth transfer of required information and the timely performance of reporting, liaison and consultation

8. In Harmony with Society and Local Communities

  • As members of society, we will participate in social contribution activities in accordance with our personal beliefs.
  • We will strive toward a harmonious and mutually beneficial relationship with local communities.

9. Separation of Corporate Business and Personal Affairs

  • We will at all times conduct ourselves based on sound judgment, and make a clear distinction between corporate business and our personal affairs.

10. Collection, Management and Usage of Information

  • We will collect information swiftly, properly and lawfully, manage it appropriately, and use it effectively.
  • We will utilize information acquired in conjunction with corporate business expressly for that purpose only, and will not leak such information to any third party

11. Handling of Intellectual Property

  • We will nurture and maintain conscious recognition of the importance of intellectual property as a vital asset of the Group, and strive toward the creation of such property.
  • We will strive to properly protect and effectively use all corporate intellectual properties; we will also respect intellectual properties of other parties.

12. Assurance of Quality

  • We will continuously improve quality management systems and provide products and services that satisfy customers.
  • We will enhance technologies and seek to engage in manufacturing that takes into account customers’ safety and their environment.

13. Stance toward Performance of Sales and Purchasing

  • We will comply with competition laws and conduct sales and purchasing activities based on fair competition.

14. Stance toward Entertainment and Gifts

  • We will entertain and present gifts to others, and accept entertainment and gifts, within the proper limits of both the law and social acceptability.
  • We will comply with laws against bribery and will maintain healthy and proper relationships with government and political organizations.

15. Severance of Relationships with Socially Disruptive Forces

  • We will staunchly eliminate socially disruptive forces and have no relations whatsoever with them.

16. Concern for the Global Environmen

  • Taking into consideration climate change and biodiversity, we will act in a manner enabling us to contribute to the resolution and/or improvement of resource, energy and environmental problems of global scale.

17. Attitude in the Performance of Global Business Activities

  • We will strive to interact with people in the countries or regions where we undertake business and engage in conduct that respects local culture and practices as well as globally accepted norms and their spirit.