Thorough Compliance

Mission 

Thorough implementation of soft-law-based compliance going beyond legal and regulatory compliance is the key principle for business continuity.
We will gain the trust of international society and people involved in our business activities through thorough compliance.

Policies

In line with its mission to sustainably grow corporate value, the company is committed to developing systems and activities to ensure compliance with the laws and regulations of each country and region, as well as the spread of ethical values based on solid integrity. The company's management takes the lead in developing thorough compliance and fosters a culture in which all employees refuse to tolerate any form of misconduct.

Promotion system

Under the leadership of the Chief Sustainability Officer (CSuO), the Compliance Planning Group within the Compliance Department introduces policies and measures to promote compliance throughout the whole Resonac group as the second line of defense. Compliance officers are assigned to each Resonac organization and major international Group companies to create a company-wide compliance promotion system.
Incidents involving breaches or violations of internal rules, laws, or regulations in Resonac's organizations and major international Group companies are immediately reported to the CSuO, the Chief Risk Officer (CRO) and the corporate auditors. Serious compliance-related matters are reported to the Board of Directors as appropriate.

Our Code of Conduct

The Resonac Group has established “Our Code of Conduct” as a guide that everyone working for the Group is expected to follow. It specifically sets out how each officer and employee working for the Group should act every day to realize our Purpose, incorporating the relationship with our Values and key sustainability issues, as well as our responsibilities to stakeholders.
“Our Code of Conduct” consistently uses “We” as the subject so that each individual takes ownership. It also explains the background and rationale underlying each action, enabling everyone to understand and act with conviction. Since the integration in 2023, we have provided employees with multiple opportunities to read “Our Code of Conduct,” offered e-learning during Corporate Ethics Awareness Campaign, and held workplace discussions. The Code has been translated into 14 languages so that all Group employees at Resonac sites can fully understand it, and we are systematically promoting its adoption through initiatives including briefing sessions at Group sites in Japan and overseas. To establish “Solid Integrity” as part of our corporate culture, the Resonac Group requires all officers and employees to confirm in writing their commitment to complying with the Code of Conduct.

• Our Code of Conduct

Measures for legal compliance

Global Compliance Standards (GCS)

With the objective of preventing corruption and avoiding contravention of competition law, the GCS defines the system and framework that Resonac must establish to meet standards of compliance required by the international community above and beyond legal compliance. Within the standard legal compliance framework set across the Group, individual Group companies establish their own rules for complying with competition laws, preventing bribery and avoiding transactions with anti-social forces in line with local conditions, locally applicable rules and the degree of business risk.
Each organization within the Resonac Group, along with major Group companies in Japan and overseas, conducts self-audits to assess the development and operation of their compliance promotion systems. In addition, the Compliance Planning Group of the Compliance Department provides training sessions using real-life compliance cases as learning material. These initiatives reflect our commitment to continuously improving and strengthening our compliance framework. Furthermore, based on trends in compliance incidents and the results of monitoring and reviews, each organization develops its own compliance enhancement measures and works to ensure the appropriate design and effective operation of the GCS.
To enable each organization, overseas bases, and major domestic and international group companies to verify their own operational status of the GCS, the headquarters compliance department carries out monitoring and continuous support for improvement.

Compliance with competition laws

Competition laws are designed to ensure fair and open competition. To meet our obligations under each country’s competition laws, we formulated our own anti-cartel rules in 2010 and have been implementing rules to control cartel risks appropriately in our daily business operations. Since 1999, the Compliance Planning Group of the Compliance Department has also been conducting an annual check for noncompliance with competition legislation and reports the results to the CSuO and the CRO.

Anti-corruption

Anti-bribery

Bribery is defined as the act of directly or indirectly offering, promising, giving, or approving an improper reward related to one’s duties. Improper rewards include not only money and goods but also anything sufficient to satisfy human desires or needs, including those exceeding an appropriate level as social courtesy or those clearly compensatory for duties, and such acts are prohibited. On the other hand, bribery is defined and prohibited as the act of unjustly receiving or requesting, directly or indirectly, money or other benefits by using the company's business position, status, or other conveniences. Bribery, coercion, solicitation, or inducement involving public officials (including those employed by enterprises effectively controlled by the government or local public bodies, officials of public international organizations, and public office candidates) or executives and employees of private companies is an act that causes corruption in the nation's political economy and hinders the sustainable growth of the international community. We have established the "Resonac Group Global Policy on Prevention of Bribery and Corruption" and related regulations on bribery and corruption prevention, and are thoroughly committed to complying with anti-bribery laws in each country. Also, it is prohibited by anti-bribery regulations in various countries and our company rules to provide, directly or through third parties, excessive entertainment or gifts to domestic and foreign public officials or officers and employees of private companies with the aim of obtaining undue commercial advantage, as well as to engage in giving and receiving, collusion, or facilitation payments. Regarding these matters, internal training is conducted for employees both in Japan and overseas. We also provide education on how to respond in order to avoid bribery risks.
Our own rules prohibit giving or receiving not only bribes but also favors, gratuitous benefits, entertainment or gifts that may be suspected of being for improper gain, and we strictly set approval processes to prevent gratuitous benefits beyond the scope of social courtesies. We are also stepping up our anti-corruption efforts in high-risk businesses and transactions. For transactions with public and quasi-public officials in particular, internal audits confirm that such transactions do not constitute bribery.
Furthermore, through our Sustainable Procurement Guidelines, we ensure that our anti-corruption policy is thoroughly communicated to all suppliers as well as intermediaries such as agents, consultants, and distributors. In addition, through CSR questionnaires conducted for suppliers, we assess corruption risks and promote efforts to prevent corruption.

Education and awareness-raising activities

We provide all directors, officers and employees with education and awareness-raising opportunities to ensure that the Code of Conduct and the GCS are widely understood and put into practice.

With regard to training, we are encouraging better understanding of the provisions of the Group’s Code of Conduct and GCS to ensure thorough compliance and honest business conduct. Furthermore, we systematically and regularly hold in-house study sessions and engage in communication activities to ensure that employees fully comprehend not only the wording of the rules but also their background and the reasons why they are necessary.

Strategy for Realizing the Long-Term Vision

Roadmap for 2030

KPI Targets and Results

Resonac positions sustainability at the core of its company-wide strategy and has identified key sustainability issues (materialities). In the area of compliance, we have established the KPIs below and are working to realize our long-term vision through the achievement of each materiality.

Compliance risk management

The Compliance Division identifies and mitigates compliance risks in advance. It conducts periodic risk assessments of all our business processes and pursues improvements to reduce risks under the ownership of our business execution divisions based on the risk management approach we are taking on a global basis. An internal reporting system has also been established to allow employees to report any violation or suspected violation of laws, regulations, etc., and we promptly investigate the facts, determine the causes, and take action to correct the situation and prevent recurrence. The personal information of whistleblowers is strictly protected, and whistleblowers are never treated unfairly.
In addition, if it is found that a reporter has been dismissed or subjected to other unfavorable treatment as a result of making a report, appropriate remedial and restorative measures will be taken.

The Code of Conduct clearly states that executives and employees may not accept gifts, entertainment, or other benefits from business partners or company customers that are beyond the scope of social common sense, may not provide similar benefits to government agencies, business partners, or company customers, and may not engage in any acts that may give rise to conflicts of interest or insider trading.

Tax compliance

The Resonac Group has established the Group Tax Policy based on the recognition that it is one of the social responsibilities of an enterprise to contribute to society’s growth through tax payment in all countries and regions where it conducts business activities. We will make appropriate and prompt responses to the taxation system and regulations of each country and region, while continuing to provide employees with training to maintain and raise their tax compliance awareness.

• Resonac Group’s Tax Code of Conduct
• Disclosure of Country-by-country Report (CbCR)