Compliance (environmental/social and economic)

Material Issue Compliance (environmental/social and economic)

  • Targets/Vision
  • Violation of environmental laws and regulations: None
  • Compliance with the political donation policy
  • Order or recommendation due to violation of the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors (“Subcontract Act”) : None
  • Violation of laws and regulations on security export control: None
  • Information leakage: None
  • Infringement of intellectual property rights: None
  • Develop internal regulations reflecting the latest revision of laws, provide related education and conduct proper monitoring of the operation status

Management and Promotion Method of Compliance (environmental/social and economic)

[Responsible Departments]
  • General Administration Department
[Policy/Point of view]

The Bando Group positions compliance with laws and regulations and corporate ethics as a major premise for the promotion of our business activities and strives to conduct business activities based on social decency to be a company trusted by society. From such perspective, we established the “Group regulations on legal compliance, etc.” to ensure compliance with laws and regulations and corporate ethics, based on which the “internal reporting system” and the “reporting system for business partners” were established. We also compiled rules to be complied with by officers and employees regarding compliance with laws and regulations and corporate ethics, fair transactions and information management including prohibition of insider trading as the “Group Code of Conduct,” and all officers and employees are required to carry the Code of Conduct leaflet with them. In addition, we hold an annual Code of Conduct workshop for officers, department managers, and responsible persons of affiliates, and each department and affiliate holds discussions about the Code of Conduct and actual corporate scandals.

[Targets/Vision]

Violations: None

[Measures]
  • Distribute the Group Code of Conduct leaflet
  • Conduct Code of Conduct workshops and discussions about the Code of Conduct, etc.

●Compliance with environmental laws and regulations

[Responsible Departments]
  • Safety and Environmental Promotion Department of Manufacturing Planning Center
  • Business divisions, research laboratories
[Policy/Point of view]

The “Group Code of Conduct” stipulates compliance with laws and regulations and corporate ethics, and the “Basic Environmental Policy” stipulates compliance with environmental laws and regulations and agreements with local governments and industries, etc. We maintain the latest version of the environmental laws and regulations, etc. to be observed and evaluate the status of compliance with applicable laws and regulations at business facilities in accordance with the “Environmental Guidelines” prepared based on the environmental management system ISO14001.

[Targets/Vision]

Violations of environmental laws and regulations: None

[Measures]
  • Conduct an environmental assessment based on the Environmental Guidelines when installing facilities
  • Appropriately register facilities regulated by the environmental laws and regulations
  • Perform environmental measurements of facilities regulated by the environmental laws and regulations
  • Provide employee education based on the “environmental management system” and the “environmental education manual”

●Prevention of insider trading

[Responsible Departments]
  • General Administration Department

The Group established and implements the “Group regulations on prevention of insider trading” to prevent insider trading.

●Elimination of antisocial forces

[Responsible Departments]
  • General Administration Department

Necessary provisions are prescribed and included in the master transaction agreements to eliminate antisocial forces.

●Compliance with the Political contributions policy

[Responsible Departments]
  • General Administration Department
[Policy/Point of view]

Donations to political and other groups are governed by the approval rules under the “Political contributions policy.

[Targets/Vision]

Compliance with the Political contributions policy

●Compliance with the Subcontract Act

[Responsible Departments]
  • Procurement Department of Manufacturing Planning Center and procurement division of each business facility
[Policy/Point of view]

To comply with the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors (“Subcontract Act”), the “Procurement policy” clearly stipulates fair transactions as one of the basic principles, and all government notices and implementation standards related to the Subcontract Act are shared within the Company to ensure all employees are informed of and understand the items they must comply with.

[Targets/Vision]

Order or recommendation due to violation of the Subcontract Act: None

[Measures]
  • Relevant personnel participate in seminars organized by competent authorities
  • Provide education on the Subcontract Act to persons in charge of procurement in Bando Chemical Industries and affiliates
  • Specify cash settlement as the method of payments to subcontractors of Bando Chemical Industries

●Compliance with of laws and regulations on security export control

[Responsible Departments]
  • Group companies administration department
[Policy/Point of view]

Recognizing the importance of the security export control, the Group established the “Group export control regulations” and the “Export control rules” and is using the export control system set forth by these regulations and rules to control export in accordance with relevant laws and regulations in cooperation with business departments.

[Targets/Vision]

Violation of laws and regulations on security export control: None

[Measures]
  • Create a list of managers and persons in charge of export control
  • Develop education curriculum and provide education (briefing sessions within and outside the Company and seminars)
  • Check the compliance status regularly and improve

●Information security

[Responsible Departments]
  • Corporate Information Systems Department
[Policy/Point of view]

For information security, the Group stipulates strict management of confidential information in the “Group Code of Conduct” to maintain and prevent leakage of such information and manages information and provides information security education to all employees and temporary staff in accordance with the “Group IT governance regulations.”

[Targets/Vision]

Information leakage: None

[Measures]
  • Provide information security education
  • Implement measures against information leakage through external memory media
  • Encrypt hard disc of mobile PCs

●Respecting the third parties’ intellectual property rights

[Responsible Departments]
  • Intellectual Property Group, Research Laboratories for Core Technologies
  • Engineering divisions
[Policy/Point of view]

The Group’s intellectual property activities are conducted based on the “Rules on promotion of patent strategy” under the principle for respecting intellectual property rights to actively acquire and utilize intellectual property rights useful for our business activities and to appropriately handle the third parties’ rights.

[Targets/Vision]

Infringement of intellectual property rights: None

[Measures]
  • Plan and provide new recruit education as well as level-based intellectual property education to engineers
  • Build a system environment capable of reliably and speedily obtaining a vast amount of information on third parties’ rights that is updated daily
  • Establish a system that allows to appropriately handle the third parties’ rights through close collaboration between the engineering division and the intellectual property division

●Compliance with labor-related laws

[Responsible Departments]
  • Personnel Department
  • Business facilities
[Policy/Point of view]

The Group sets forth the compliance with laws and regulations and corporate ethics, and respect of human rights, personality and individuality in the “Group Code of Conduct”, and aims at creating safe, comfortable and pleasant workplace atmosphere. Revisions of labor-related laws are reflected in the labor-related regulations to ensure such revisions are appropriately handled and informed to all employees.

[Targets/Vision]

Develop internal regulations reflecting the latest revision/enforcement of laws, provide related education and conduct proper monitoring of the operation status

[Measures]
  • Ensure to obtain the latest information on revisions, etc. of laws and their handling and measures through the use of a legal revision information notification service and the information exchange with the Japan Rubber Manufacturers Association and other economic associations
  • Consider the need for revision of internal rules
  • Ensure that rules are made available to all relevant employees at any time and that laws and regulations and rules that are particularly relevant to the Group are covered by information sharing meetings for relevant personnel and internal trainings
  • Conduct monitoring through initiatives by the Risk Management Committee and the Legal Compliance Committee and the self-assessment results of the internal control evaluation

Raising awareness of compliance and promotion system

The Group has formulated and distributes to all Group executives and employees the Bando Group Code of Conduct, which stipulates proper actions in such areas as “compliance with laws and corporate ethics,” “product and service safety,” “honest and fair business activities,” and “fair and equitable procurement transactions.” In addition, the Group works to raise awareness of compliance by designating October as the Bando Group Corporate Ethics Month, holding workshops on the Bando Group Code of Conduct and providing opportunities to discuss these topics internally. Moreover, the Group has established a system to further promote compliance by adopting an internal reporting system that includes external lawyers as well as a service for providing information on the formulation, revision and abolition of relevant laws.
In fiscal 2020, we implemented measures including “increase in contact offices,” “acceptance of anonymous reporting,” and “reinforcement of confidentiality obligation of those involved in the investigation” to improve the effectiveness of our internal reporting system.

Environmental compliance

For environmental compliance, the Group conducts environmental assessment based on the environmental manual when installing facilities, adequate notification of facilities regulated by environmental laws and regulations and environmental measurement, employee education based on the “environmental management system” and the “environmental education manual.”
For environmental compliance, the Group conducts environmental assessment based on the Environmental Guidelines when installing facilities, adequate notification of facilities regulated by environmental laws and regulations and environmental measurement, employee education based on the “Environmental Manual” and the “Environmental Guidelines.”
In fiscal 2020, we conducted the environment patrols at each business facility to ensure they are properly implemented (at least once in each business facility) and also started to review the environmental legal compliance system in each business facility based on the results of the company-wide five-part trainings on environmental laws and regulations conducted by external experts in the previous fiscal year.
In fiscal 2020, there was no violation of environmental laws and regulations resulting in material penalty or sanction. In fiscal 2021, we set a month during which we make a concentrated effort to confirm management status and strengthen enlightenment. We will also conduct regular patrols for the prevention of environmental pollution and make proposals for improvement of water treatment diagnosis systematically.

Socioeconomic compliance

For socioeconomic compliance, the Group is working on the following initiatives: ensuring corporate ethics; prevention of insider trading and bribery/corruption; elimination of antisocial forces, clarification of political donations policy; compliance with the Antimonopoly Act and Subcontract Act; strengthening the security export control system; measures for information security; respect of intellectual property rights of third parties (including trade secrets); and amendments to labor-related regulations to reflect legal revisions and their dissemination.
As a part of our initiatives on global tax compliance, we are taking measures for BEPS* and also introduced the “reporting system for business partners” for early detection and correction of violations of relevant laws and regulations by the Group’s related parties.
In fiscal 2020, there was no violation, infringement, leak, or breach in any of these matters.

*BEPS: Base Erosion and Profit Shifting

  • Targets/Vision
  • ● Violation: None

Management and Promotion Method of Anti-corruption/Anti-competitive behavior

[Responsible Departments]
  • General Administration Department
  • Each Sales Division
[Policy/Point of view]

The Bando Group positions compliance with laws and regulations and corporate ethics as a major premise for the promotion of our business activities and strives to conduct business activities based on social decency to be a company trusted by society. From such perspective, we established the “Group regulations on legal compliance, etc.” to ensure compliance with laws and regulations and corporate ethics, based on which the “internal reporting system” and the “reporting system for business partners” were established. We also compiled rules to be complied with by officers and employees regarding compliance with laws and regulations and corporate ethics, fair transactions and information management including prohibition of insider trading as the “Group Code of Conduct,” and all officers and employees are required to carry the Code of Conduct leaflet with them. In addition, we hold an annual Code of Conduct workshop for officers, department managers, and responsible persons of affiliates, and each department and affiliate holds discussions about the Code of Conduct and actual corporate scandals

[Targets/Vision]

Violations: None

Violations: None
  • Distribute the Group Code of Conduct leaflet
  • Conduct Code of Conduct workshops and discussions about the Code of Conduct, etc.

Carry “Group Code of Conduct” leaflet

In order to prevent corruption and anti-competitive behavior, the Group established the “Group regulations on legal compliance, etc.” and set up the “internal reporting system,” and also compiled rules to be complied with by officers and employees as the “Bando Group Code of Conduct” which officers and employees are required to carry with them. We also hold Code of Conduct workshops for officers and employees every year, hold lectures pertaining to the corrupt practices prevention laws for employees dispatched to overseas affiliates, and established and put into practice the “Group bylaw for compliance with the Antimonopoly Act” and “Group bylaw concerning activities for trade association” for the prevention of anticompetitive behavior.
In fiscal 2020, there was no violation related to these matters.