As a framework for thorough compliance, we have established a Charter of Corporate Behavior and a Code of Conduct for Executives and Employees based on our Corporate Philosophy. We place the highest priority on thorough compliance in all of our corporate activities. In addition, as our sustainability and compliance promotion system, we have established the Executive Sustainability Committee, chaired by the president, as the command center for group-wide sustainability initiatives. We also established the OVOL Sustainability Promotion Meetings, consisting of members appointed from each division, branch office, and group company, as a cross-organizational entity to promote sustainability and compliance.
The group revised its Charter of Corporate Behavior in April 2022 in order to further promote sustainable management. The charter is a guide for ensuring that all executives and employees recognize the values that have been cultivated over the years, and constantly embody them.
The Code of Conduct for Executives and Employees, which was also revised in April 2022, is based on the Charter of Corporate Behavior and defines the values and actions that should be pursued by executives and employees of the group in their daily business activities in order to achieve the goals of the Sustainability Policy. 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.
We strive to be a company that is trusted by society due to our free, fair, and transparent business activities. The 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 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 and declared our commitment to 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 Act in relation to a bid for recycled roll paper with the National Printing Bureau. We take this matter seriously, and will fully cooperate with the Japan Fair Trade Commission’s investigation.
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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 to ensure that executives and employees are fully aware of the importance of compliance and have the knowledge and information necessary to put it into practice. In addition, the group posts the Compliance Magazine on the company’s internal bulletin board twice a month and the Compliance Letter in the group’s magazine four times a year. Our goal is to regularly disseminate information to executives and employees and to raise awareness of compliance.
Compliance awareness activities (Fiscal 2022) | Target | Frequency of meetings | Number of participants |
---|---|---|---|
Rank-based compliance training | New employees, new managers, and seconded employees of Japan Pulp & Paper | 4 times | 38 |
Harassment prevention training | Deputy section managers and assistant managers (including seconded employees) of Japan Pulp & Paper | 5 times | 232 |
Antimonopoly Act seminar | Executives and employees of Japan Pulp & Paper | 1 time | 913 |
e-learning tests | Executives and employees of Japan Pulp & Paper and group companies in Japan | 2 times | Average: 1,873 |
Information on amendment to Act on the Regulation of Chemical Substances | Sales department managers of Japan Pulp & Paper | 1 time | 61 |
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.
The content of the whistleblower reports and responses are conveyed to the representative director president and Audit & Supervisory Board members, and the Internal Audit Office regularly monitors the operational status of the whistleblower system as part of internal control.
In fiscal 2022, we received 13 whistleblower reports, nine of which were anonymous. The reports tended to be issues related to harassment and labor relations.