The Compliance Sub-Committee is the primary organization accountable for checking compliance with relevant laws and ordinances closely related to the Group’s business, such as the Construction Industry Act and the Licensed Architect Act. In addition, it carries out initiatives so that it may fully understand and manage the compliance situation and to increase awareness about it throughout the Group to ensure compliance with relevant laws in those of its businesses that require official approval.
Also, some parts of the Company’s businesses require that it enters into contracts with multiple external specialists, such as from the construction industry, and we thoroughly manage the various approvals required by outsourcers.
To improve the compliance of each and every employee, group training is carried out not only for new employees but also for employees at each staff level, such as for managers and general managers. The Group’s e-learning program is a required training course for all Group employees. Also, whether within Japan or overseas, all employees complete a training course on starting work at a Group company and then as required throughout the careers.
The Group held seminars for the compliance managers of all Group companies led by external specialist instructors. In fiscal 2011, the Group organized seminars on such topics as the Revised Waste Management Law and on the practise of using product accident risk maps. The Revised Waste Management Law seminar was held in April 2011 and attendees were taught about their responsibilities following the revisions to this law, which pertain to the integration of the responsibilities of the main contractor for construction-related waste and also the processing of industrial waste. 50 working-level managers whose responsibilities include industrial waste attended the seminar and through quizzes, an explanation of the most important aspects of the law, and lectures from lawyers specializing in this field, they were able to deepen their understanding of this law and thereby better comply with it.
In the practical seminar on product accident risk map, the R-map method, which is used as a reference for the recall judgment by the Ministry of Economy, Trade and Industry and also complies with international standards, was introduced to learn how to ensure customer safety for the Group’s core businnes of detached housing. The detached housing is composed of many products and parts that are procured from outside the Group and attendees learned the visualization process of risks so as not to put customers through defective products. 52 employees attended this seminar, including from the Materials Procurement Department and from the Quality Control & Customer Information Department.
In 2002, the Sumitomo Forestry Group established the Compliance Counter to improve our ability to regulate our own day-to-day business activities through rapidly detecting illegalities and other difficult-to-resolve forms of misconduct and nipping them in the bud before they develop into serious issues. The Group has two compliance counters, one within the Group and one outside it, and has in place a framework to enable those who contact the counters for advice or to report a compliance violation to consult the relevant regulations and a user manual and to ensure that their interests will not be harmed.
The Group revised this manual in fiscal 2011 and it distributes it to all of its approximately 12,500 Group employees, including non-full time employees, and has been carrying out a range of initiatives to enable as many people as possible to easily get advice and report a suspected violation. These initiatives including using the Intranet to increased awareness about the compliance windows, creating an email address only for use for contacting the compliance counters, and including in the user manual the photographs of the male and female lawyers who are available for consultations on the external compliance counter. As a result of these efforts, in fiscal 2011 the Compliance Counter was contacted 25 times, a substantial increase on the 12 times during the previous fiscal year.
When a compliance violation occurs, Sumitomo Forestry first aims to fully understand what actually occurred. The Compnay then formulates measures to prevent its reoccurrence and to ensure compliance in the future, while also appropriately disclosing information relating to the violation.
After establishing precisely what occurred, we punish the employee responsible for the violation in accordance with the relevant laws and Company regulations.
The Group periodically holds study meetings for the compliance managers that it appoints to conduct oversight within Group companies. In addition, internal auditors, members of the Internal Audit Department, and risk and compliance managers meet every month to report to share information on managing risk at every level within the Group.
The Group places the highest importance on a corporate spirit that earns it the trust of society and it instructs its employees never to engage in behavior for personal gain that would damage this trust, to always obey society’s rules and laws, and to compete in a fair and dignified manner.
Securing healthy profits in an environment of free and fair competition
The Company used the opportunity provided by the January 2010 revision of the Antimonopoly Act to investigate actual conditions relating to its associations with its competitor companies. The results of this investigation enabled it to better grasp its various situations and judge how serious they are. Further, in order to ensure employees fully understand the risks from interactions with competitors, the Company issued a guide book that includes not only a summary of the relevant laws but also sections on matters of importance and the correct approach to take when associating with other companies.
The Group’s basic policy is to protect the intellectual property that it creates and to deal decisively with any violations to its intellectual property rights.
Sumitomo Forestry sets forth in 2007 the new Ethics and Behavior Code, “Our Values and Ideals,” institutionalizing the long-held principle of “Influence from anti-social elements will be met with a resolute attitude and no compromises will be tolerated.” This stance has been communicated widely both within and outside the Group. In accordance with this policy, all contracts that the Group enters into include a clause to exclude anti-social elements.