In order to ensure fair and honest business practices, the Nisshinbo Group conducts a variety of compliance training, such as training for different employee levels and work sites and training for employees who will receive assignments abroad.
Since fiscal 2016, in order to instill compliance the Group has made conducting yearly compliance training for all of its managers one of its KPIs. We have created Compliance Training Materials for Managers in both Japanese and English and are utilizing them at all Group companies.
Additionally, we are conducting training at all of our subsidiaries that is tailored to each company’s country, region and type of business.
In recent years, international legislation on bribery and corrupt practices have been strengthened, and detection has grown more rigorous. In the Business Conduct Guidelines of the Nisshinbo Group, we have defined our initiatives in this area, through which we work to prevent violations. In fiscal 2015 we formulated the Guide to Prevent Corruption in response to related legislation in other countries. We have rolled out the guide across the Group, including all subsidiaries in other countries. This guide encompasses Article 18 of Japan’s Unfair Competition Prevention Act (Prohibition to Provide Illicit Gain, etc. to Foreign Public Officers, etc.), the United Nations Convention against Corruption (UNCAC), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the U.S. Foreign Corrupt Practices Act (FCPA) and related guidelines, and the UK Bribery Act. In fiscal 2017, revising the guide to correspond to the up-to-date information, we continued to use it at all subsidiaries.
Adhering Strictly to a Policy of Confidentiality
Regarding information concerning intellectual property, technology and know-how that is shared during collaborative discussions with suppliers from the design and development stages, we take steps to conclude confidentiality agreements and to prevent any leakage of such information.
Each year, we conduct internal audits of trade secret management to ensure that proper confidentiality is maintained.