Compliance

The JCU Group recognizes the importance of its corporate social responsibilities, and in order to fulfill our responsibilities, has established the “JCU Code of Conduct” as a c ode of compliance and ethics.

Promoting Compliance

Based on the JCU Code of Conduct, the JCU Group always complies with relevant laws and internal rules in all aspects of our corporate activities, and promotes compliance so that all of our corporate activities comply with normal business practices and social ethics.

This Code of Conduct has been translated into seven languages other than Japanese: Chinese (Traditional and Simplified), Korean, English, Vietnamese, Thai, Spanish, and Indonesian. The Code of Conduc t translated into each language is communicated to respective local subsidiaries in light of local customs and laws.

Furthermore, our Corporate Philosophy, CSR Policy, JCU Spirit, and Code of Conduct are distributed to all executives and employees of the JCU Group to ensure that they are all well-informed.

JCU Code of Conduct

Compliance Promotion System

The JCU Group has a Compliance Committee (chaired by the President and CEO) under the Board of Directors where top management take their own initiative in driving compliance forward.

The Compliance Committee is made up of internal directors and a number of Executive Officers. A meeting of compliance management leaders appointed by individual departments is installed under this Committee. Compliance management leaders make every effort to gather information on legislative revisions and gain an understanding of issues through subcommittees and other organizations for each of the different areas of laws and regulations. The Compliance Management Leaders Meeting discusses the sharing of practical information within the company and matters that should be reported to the Committee, and the content of these discussions are promptly reported to the Committee. The Commit tee reviews the report from a management perspective, decides what actions to take as a company, and has the relevant departments execute on these decisions.

Compliance promotion system

Compliance Promotion System

Installed the Internal and External Reporting Desk

For the purpose of detecting and correcting misconduct at an early stage, and to help strengthen our compliance, the JCU Group has a desk for internal and external reporting, and a system for properly acting on reports given by JCU Group exe utives and employees , as well as business partners, etc., on legal and regulatory violations committed by organizations or individuals.

Internal and external reporting desk

Nagamatsu & Yokoyama Law Office

Person in charge: Toshihide Yokoyama, attorney-at-law

Room 806, 8th Floor, Kioicho Building, 3-12 Kioicho, Chiyoda-ku, Tokyo 102-0094, Japan

FAX: 03-6910-0746Email: jcu.hotline@n-lo.com

Compliance Initiatives

We hand out booklets to ensure that
people are well-informed.

The JCU Group has established rules and guidelines, organizes training, and prepares and distributes manuals in order to ensure that everyone is well-informed on the Basic Code of Conduct which represents our basic approach to compliance. In addition, we conduct internal audits of the Group to detect problems at an early stage.

In terms of activities to promote compliance, we are looking into providing training on applicable laws and regulations at each office.

The Niigata Plant, R&D Center, and overseas subsidiaries hold study sessions on business-related laws , and on chemicals that require special attention for handling. We also advance compliance by conducting checks on the levels of employees’ understanding and evaluations of their abilities.

Installed the Compliance Consultation Desk

Apart from the internal and external reporting desk, the JCU Group also has a compliance consultation desk that makes it easier for persons to seek consultation on compliance-related questions that they may have about the company. Information on the compliance consultation desk is provided in the Compliance Manual posted on the intranet to ensure that everyone is well-informed.

Initiatives to Eliminate Antisocial Groups

The JCU Group has set out the elimination of antisocial groups in its Code of Conduct. We have no relationships with antisocial forces or organizations that pose a threat to social order or sound corporate activities, and make every effort to eliminate such groups in cooperation with competent authorities and relevant organizations.

Legal Department’s Activities to Promote Compliance

Legal Section,
Legal Department Yoshiaki
Shirakawa

Legal Section, Legal Department Yoshiaki Shirakawa

In promoting compliance, JCU strives to identify problems as early as possible and raise the awareness of each and every employee. In this context, the Legal Department regularly gives a “Compliance Quiz” for all employees as part of its activities to promote compliance. The program has been conducted in the past in a format where each student would study at their own desks, but we have significantly renewed this format in October 2022. Training materials are revised in accordance with our Code of Conduct and regulations, made easy to read in a cartoon style, and the quizzes are given every two weeks.

To ensure that no compliance violations occur in any area of our operations, the program is for all employees̶not only full-time employees, but also employees on loan overseas and temporary staff. While some chose not to respond to the quiz initially, the quizzes took root over the past year to the point where we now have a 98% response rate. The quizzes cover a comprehensive range of topics, and this has helped raise the baseline level of knowledge of laws and regulations, and improve awareness throughout the company.

Law is a highly specialized field, and at first glance, people may feel that it doesn’t have much to do with them, but the Legal Department believes that by making people aware of how closely it relates to them and helping them to overcome this sense that it is too difficult, all employees can become aware that they are actually in the driver’s seat when it comes to legal compliance. We will continue our activities to promote compliance and strive to make the Legal Department an “easy-to-consult” place where people are welcome to come in with questions on legal topics.