Strengthening and Promoting the Compliance System
Compliance
Basic Approach
The SWS Group has established a code of conduct for ethical business practices that all directors, officers and employees must follow regarding regulatory compliance, fair competition, anti-bribery efforts, protection of confidentiality and intellectual property, respect for human rights and environmental protection.
Compliance System
We share and practice the spirit of acting with high ethical standards per the Code of Conduct as a guideline for daily business operations. The Compliance Committee, chaired by the officer in charge of legal affairs, meets regularly to formulate and implement measures for conducting business activities in compliance with laws, regulations, and ethics to identify, analyze, and counter compliance risks.
In addition, we have established a legal risk reporting system for quickly and comprehensively grasping information on potential or apparent legal risks at each group company and taking prompt countermeasures.
Compliance Training
For the SWS Group to gain the trust and confidence of stakeholders and achieve sustainable growth, each employee must develop a compliance mindset and act according to good corporate citizenship. In addition to conducting annual training for directors and corporate auditors, we focus on training and enlightenment based on the characteristics of each workplace by setting reinforcement items for each year.
We strive to raise employee awareness with group newsletters that cover issues of harassment, subcontracting law, and information leaks through social networking services for new employees, cases that may occur in the course of work. In addition, since fiscal 2020, we have been distributing newsletters in Japanese, Chinese, and English to our group companies on public trends, such as bribery and competition laws, as well as legal amendments and enforcement status.
For overseas offices, we systematically conduct training on competition law and anti-bribery. In fiscal 2019, we started training for key personnel. In addition, we introduced e-learning to some training programs to prevent the spread of COVID-19. We will continue to expand online course channels in fiscal 2023.
Contacts for Compliance Reporting
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 Department as well as an external contact operated by our corporate legal counsel. In November 2019, we also established an online external contact that can be accessed from both Japan and overseas sites. Reports of non-compliance are mainly investigated and handled by the Compliance Committee Secretariat. In fiscal 2022, 103 incidents (51 harassment cases, 19 general labor cases and 33 others) were reported, investigated, and otherwise appropriately addressed.
Anti-bribery
We have established a bribery prevention program and are working to prevent bribery. In February 2018, we changed the operation of our anti-bribery program to focus on managing high-risk cases, including entertainment and gifts targeted at public officials. In addition to this, a special anti-bribery activity was launched in FY2018 to monitor companies that have particularly high contact with public officials on a quarterly basis. We are continuing to make gradual improvements by systematically reducing the number of companies that are considered to be at particularly high risk of bribery geographically.
In FY2022, monitoring was conducted for five companies in Vietnam and Philippines. (Conducted online to prevent transmission of new coronary infections)
Formulation of Basic Procurement Policies
SWS considers procurement to be a “service that supports the foundation of its business activities,” and established the Procurement Policy
Based on mutual trust and partnership with our suppliers, we have been developing procurement activities that are fair, just, and consider the global environment. In response to recent social demands for more specific activities, such as respect for human rights and climate change issues, we established the Supplier Code of Conduct in 2022. These policies, etc., have been made known not only to group companies but also to our major suppliers, and we ask for their understanding and cooperation in the Group's procurement activities.
Procurement Policy
Our procurement activities reflect our commitment “Connect with the Best” and are conducted under the following policies.
① Provide open and fair opportunities
② Adhere to basic principles of mutual understanding, mutual reliance, and mutual enlightenment
③ Establish global partnerships
④ Ensure compliance
⑤ Promote green procurement
Supplier Code of Conduct
SWS Group seeks to do business with suppliers that share our commitment to integrity and to conducting business in compliance with the law. The Supplier Code of Conduct is a statement of the values and the standards of conduct that we expect of each supplier, subcontractor, agent, consultant, or distributor. It is applicable to all suppliers to SWS Group companies worldwide.
Environmentally Hazardous Substance Control & Green Procurement Guideline
Conflict Minerals
To fulfill our social responsibility in procurement activities, we aim to be conflict-free by not using conflict minerals* as raw materials.In addition to clearly stating our policy in the SEI Group Supplier Code of Conduct, we conduct an annual survey on conflict minerals with our suppliers.
We also conduct a survey on conflict minerals with our suppliers every year.
Efforts to Strengthen Compliance with the Subcontract Act
We have implemented initiatives to strengthen and promote appropriate transactions with our subcontractors in line with the revised Subcontract Act Operation Standards and revised promotion standards under the Act on the Promotion of Subcontracting Small and Medium-sized Enterprises, which details rules concerning transactions between subcontracting companies and subcontractors governing price determination, cost bearing, and payment conditions.
Communication with Suppliers
Sumitomo Wiring Systems convenes the annual Global Suppliers Meeting to promote mutual trust with suppliers. There we provide an overview of our business environment of our harness business, share our procurement policy and key measures, and request the active commitment and initiative of our suppliers to make sure everyone is on the same page. We have also been making similar efforts overseas since fiscal 2018. The meeting includes an award ceremony recognizing outstanding suppliers based on a comprehensive evaluation conducted from standpoints including quality, cost, and delivery (QCD).
Glossary
*Tantalum, tungsten, tin, gold or their derivatives mined in the Democratic Republic of the Congo or adjoining countries and their transactions are used to fund armed forces that commit serious human rights violations.