The group recognizes compliance as one of the most important aspects of promoting sustainable management and has identified it as a material issue. Furthermore, our Charter of Corporate Behavior and Code of Conduct for Executives and Employees mandate strict adherence to laws and regulations based on our Corporate Philosophy. In addition to legal compliance, the group also promotes adherence to the Charter of Corporate Behavior, various regulations, societal rules, customs, and other social norms through education provided to executives and employees. To ensure thorough implementation, we promote compliance within each organization through the OVOL Sustainability Promotion Meetings, under the direction of the Executive Sustainability Committee.
The Japan Pulp & Paper Group’s Charter of Corporate Behavior is a guide for ensuring that all executives and employees recognize the values that have been cultivated over the years, and constantly embody them. It is also part of efforts to further promote sustainable management. The Code of Conduct for Executives and Employees defines the values and actions that should be pursued by executives and employees of the group in their daily business activities. We will ensure that all executives and employees are fully aware of these charters, norms, and policies, and work to foster a stronger understanding of compliance.
The Japan Pulp & Paper Group Code of Conduct for Executives and Employees states that we comply with the competition laws of each country and region we serve, work to prevent violations, and will establish internal systems to correct violations should they occur. We also prohibit bribery and any other acts that may be suspected of offering benefits that may be deemed for illicit gain, forbid the giving and receiving of gifts, entertainment, and other economic benefits beyond the scope of social etiquette, and require employees to refrain from any involvement in illicit business transactions and money laundering. Furthermore, in order to maintain transparency and promote business activities on an equal and fair basis, we have established an Anti-Corruption Policy. Under the supervision of the Board of Directors, we are implementing an anti-bribery and anti-corruption program aimed at preventing bribery of public and government officials as well as inappropriate demands of business partners.
On April 11, 2023, the Japan Fair Trade Commission conducted an on-site inspection on the suspicion of violation of the Antimonopoly Law in relation to a bid for recycled roll paper with the National Printing Bureau. On March 14, 2024, we received notification that the company was found to have been involved in the violation. In connection with this matter, we petitioned the Japan Fair Trade Commission for the leniency program, voluntarily reported past violations, and fully cooperated with the commission’s investigation. In the end, we did not receive a cease-and-desist order or a surcharge payment order. We take this matter seriously and have formulated measures to prevent a recurrence, some of which have already been implemented to ensure compliance with the Antimonopoly Law. Going forward, we will continue to enhance compliance with the Antimonopoly Law and ensure adherence with all other aspects of compliance. We will steadily work to prevent a recurrence and implement the prevention measures formulated in response to this matter.
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The Japan Pulp & Paper Group’s Taxation Policy states its commitment to contributing to economic and social development and the interests of all stakeholders by paying appropriate taxes in accordance with the relevant laws and regulations of all countries and regions where it operates. The policy also clarifies our basic approach to tax compliance. For important tax-related issues, the group receives advice from external experts and consults with tax authorities in advance, as necessary, in order to minimize tax risks.
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The group conducts annual educational programs such as rank-based and theme-based compliance training and e-learning. In addition, the group posts the Compliance Magazine on the company’s internal bulletin board twice a month, presents the Compliance Letter in the group’s magazine four times a year, and creates compliance awareness posters. Our goal is to regularly disseminate information to executives and employees and to raise awareness of compliance to ensure they have the knowledge and information necessary to put it into practice.
Compliance awareness activities | Target | Frequency of meetings in fiscal 2023 | Number of participants and participation rate |
---|---|---|---|
Rank-based compliance training | New employees, new managers, and seconded employees of Japan Pulp & Paper | 3 times | 41participants |
Harassment prevention training | Non-managerial employees | 1times | 616participants |
e-learning tests | Executives and employees of Japan Pulp & Paper and group companies in Japan | 2 time | Average participation rate: 99.3% |
Information on amendment to the Act on the Regulation of Chemical Substances | Japan Pulp & Paper managers | 1 times | 7 participants |
Some companies within the group have established dedicated internal and external contact points for whistleblowing on violations of laws and regulations, internal irregularities, and acts in violation of corporate ethics by executives and employees, in accordance with the Corporate Ethics Helpline Operating Regulations. In addition, the Internal Audit Office regularly monitors the operational status of the whistleblower system as part of internal control.
In fiscal 2023, we received reports from whistleblowers regarding 30 different cases and a large number of the reports involved personal criticism of superiors or colleagues. Regarding the reports, we have appropriately set the scope of information sharing and, depending on the content, consult with legal counsel. We then respond earnestly to reports and work toward resolving any issues.