Communication of our basic social responsibilities
We have declared our commitment to thorough compliance in AISIN Group Principles of Corporate Behavior. We have also formulated and communicated to all employees the Guidelines in Compliance with Social Responsibility to put the philosophy underpinning these principles into practice. The president himself is leading our efforts to reinforce compliance.
Furthermore, in concert with the revision of the AISIN Group Principles of Corporate Behavior, we strive to communicate them to all employees, having prepared a take-along AISIN Group Principles of Corporate Behavior card and distributed it to all employees, and having enabled all employees to confirm the Principles at any time on our website.
AISIN Group established a Business Ethics Committee (also known as the Consolidated Business Ethics Committee) in April 2018 to assess matters concerning legal compliance and other important points of corporate ethics and make policies. Regular meetings of this committee are held. Comprising the presidents and compliance officers of each of the 13 main group companies, the Consolidated Business Ethics Committee sets policies on compliance activities and checks that everyone in AISIN Group is complying with laws and regulations such as Antimonopoly Act and anti-bribery regulations.
Providing compliance training
Ultimately, the work of compliance is done by people. We provide training for employees at each level and additional training for our management and officers to ensure that everyone in AISIN Group is fully aware of their compliance responsibilities.
Since FY2019, members of the legal affairs division of our group headquarters have provided compliance training directly to representatives of each division of our consolidated domestic companies. Relevant divisions also receive training on points such as the Antimonopoly Act and safe and secure export management.
Every October is AISIN Group Business Ethics Campaign Month. It is a time for all employees to reflect on what they do on a daily basis and think about ethical corporate activities. All employees at our consolidated domestic companies are surveyed about their awareness of compliance during this month. Approximately 79,000 responses to the survey in FY2020 indicated that compliance awareness in our workplaces has become stronger and more widespread.
Employees at our overseas subsidiaries also receive training on ethical corporate behavior from their local compliance divisions. In North America, for example, training on points such as antimonopoly laws and harassment is carried out based on the local situation.
The AISIN Group has declared in its Principles of Corporate Behavior that it builds healthy and proper relationships with the government and administration, and never has any relationship with antisocial forces or organizations.
Furthermore, the AISIN Group regards anti-corruption as priority area in compliance, and established the AISIN Group Anti-Corruption Policy common to the AISIN Group in April 2020, based on Principles of Corporate Behavior. This policy clearly states that the AISIN Group prohibits bribery, corruption, inappropriate entertainment and gifts, and carries out proper accounting processing, which has been distributed to domestic and overseas group companies. As an action guideline for bribery, we distribute the “Guidelines on Prevention of Bribery,” to domestic and overseas group companies, making sure employees know about it.
Anti-corruption training is carried out actively at every location and level. Some areas where this takes place are 1) a topic in our compliance training for new directors in domestic group companies, 2) a topic in our stratified training in our main domestic group companies, 3) a topic in our compliance officer training in each department of our domestic group companies and, 4) a topic in our training prior to transfer for members of major domestic group companies to be transferred to overseas companies, and 5) a topic in our top management training for top managers and department managers Aisin Seiki's overseas sub-consolidated companies. Each department assesses the risk of corruption where necessary, using a risk assessment sheet.
We are making efforts to prevent corruption: When starting business with a new business partner, we conclude a basic agreement specifies that (1) both parties will comply with regulations concerning the prohibition of bribery that apply inside and outside Japan, and (2) both parties will not provide money or other benefits to third parties, including public servants, as compensation for an act of dishonesty, and (3) check whether the relevant partner company has received any directive from a public body or similar organization on suspicion of a violation of anti-bribery regulations and whether it has anti-bribery rules and frameworks in place. Also, at the time of business restructuring, etc., to confirm that relevant companies comply with laws and regulations, as required items, we check about violations not only acts concerning economy, including the anti-monopoly act and subcontracting act, but also criminal offenses, including bribery.
In terms of risk management, we carry out evaluation regarding risks, including dishonest acts of executive and staff members, illegal taking out of corporate property, bribery and other corruptive acts, through the global risk management structure, and conduct risk management activities based on the result of the evaluation.
The AISIN Group intends to address any corruption with fines, penalties and/or termination of employment in FY2019.
The AISIN Group has declared in its Principles of Corporate Behavior that it is committed to fair, transparent and open competition and appropriate and responsible business. Furthermore, the AISIN Group regards compliance with the Anti-monopoly Act as priority area in compliance as well as the anti-corruption, and established the AISIN Group Antitrust Compliance Policy in April 2020, based on Principles of Corporate Behavior.
In Japan, we are making efforts to have all employees develop an awareness and understanding of compliance with the anti-monopoly act by providing a wide range of education, including workplace manager training, training at the time of promotion for members including executives, and E-learning training. We also provide training prior to transfer for members to be transferred to overseas companies, and in overseas companies, we provide training according to the risks of each region.
Furthermore, we are making efforts to comply with the anti-monopoly act, including prior and post checking using specified forms and screening before contacting our competitors.
Detecting and correcting unethical action early with our whistleblowing service
One of the points covered during AISIN Group Business Ethics Campaign Month is thorough communication about the service we have set up for reporting and questions about compliance.
We offer consultations, both anonymously and openly, broadly from all members who work for AISIN Group companies and people connected to them, such as their family members. We strive to detect and correct violations, including sexual, power and other types of harassment, problems related to working hours, bribery, embezzlement, and insider trading, as quickly as possible.
We endeavor to detect and correct violations as quickly as possible with this service. We take thorough measures to ensure that people who make a report or comply with fact checks do not face reprisal. Confidentiality is maintained and all cooperating parties are notified first.
In FY2019, 125 reports and requests for advice regarding compliance were made throughout AISIN Group, and all have been appropriately addressed.
Similar whistleblowing services are being set up overseas, and sites in other Asian countries and North America are able to use the main group service.