Strengthening and Promoting the Compliance System

Basic Approach

"We established a compliance manual in 2005 to augment our compliance system with guidelines for daily operations. Every Sumitomo Wiring Systems employee is expected to adhere to the guidelines in the spirit of acting under the highest ethical standards. Meetings of the Compliance Committee, chaired by the director in charge of legal affairs, are held on a regular basis to reinforce this effort through the planning and implementation of measures that ensure business operations are being conducted legally and ethically and compliance risks are being identified, analyzed and dealt with. Bribery prevention in Japan and overseas remained our priority in fiscal 2016. We developed a global system by assigning 41 managers who were charged with preventing bribery in 37 Group companies in 12 countries. As part of our commitment to strengthen the monitoring and prevention of bribery, we conduct quarterly reviews of the entertainment expense reports of each department that are submitted to the Legal Affairs Department."

Promotion System

"Contacts for compliance reporting were established as an effective system for the early detection and correction of any incidents of legal or ethical non-compliance. To make filing reports easier, we set up an internal contact run by our Legal Affairs Department and also an external contact run by our corporate legal counsel. Reports of non-compliance are mainly investigated and handled by the Legal Affairs Department, which serves as the Compliance Committee Secretariat. In fiscal 2016, 11 incidents were reported, investigated and appropriately addressed."