Compliance

Dissemination of the NICHICON Group Code of Conduct (Revised)

In addition to the Company Credo, the Mission Statement defines the direction and social responsibility on which every employee should be focused. In October 2002, we established the NICHICON Group Code of Conduct as guidance for director and employee observance of laws and regulations and to spread shared ethics and values.

Since the NICHICON Group Code of Conduct was established in 2002, the Responsible Business Alliance (RBA; the former Electronic Industry Citizenship Coalition®) Code of Conduct was created and has been revised several times. In November 2010, ISO 26000 (guidance on social responsibility) was published. We have made adjustments concerning the social responsibilities called for by the EICC (now RBA) and ISO 26000, and in April 2013 we issued a revised version of the NICHICON Group Code of Conduct (with Japanese/English/Chinese/Malay editions) with extensive content enhancement.

After issuing the revised version, we are working to improve employees’ understanding by way of a Code of Conduct Understanding Checklist while giving training and sharing information at each business facility, utilizing e-learning tools and other means for all employees in Japan and overseas.

NICHICON Group Code of Conduct (revised) (published in four languages)

Provision of internal and external consultation services (Internal Reporting System)

Compliance plays a significant role in the promotion of sound corporate activities in conformity with all laws, ordinances, internal rules, policies, codes of ethics, etc.

The NICHICON Group has established an internal reporting rule as one of the mechanisms to ensure thorough compliance, and has established a “Compliance Hotline (Internal Reporting System)” based on this rule.

Specifically, points of contact and means of consultation are provided, and investigations are conducted when necessary, should reports be received. Furthermore, we thoroughly protect the personal information of the people who file reports so as to prevent them from suffering any negative effects. As such, efforts are being made for the prevention and early detection of misconduct by utilizing the Compliance Hotline.

In July 2016, the Competition Law Compliance External Reporting Hotline was established.

Enhanced structure for competition law compliance

The NICHICON Group has made an effort to engage in activities that thoroughly comply with social ethics and follow laws and rules to fulfill our social responsibility.

However, as we have been suspected of violating antitrust laws in Japan and competition laws in other countries in the past, we have been investigated by the Japan Fair Trade Commission and overseas competition authorities.

We sincerely apologize for the concern these events caused our shareholders and all other stakeholders.

The NICHICON Group takes these findings extremely seriously and strives to strengthen compliance structures and educational activities to more thoroughly comply with antitrust laws in Japan and competition laws in other countries. In an attempt to further enhance the NICHICON Group competition law compliance structure, the Competition Law Compliance Subcommittee was established under the CSR Promotion Committee in July 2016. In addition, competition law compliance regulations were formulated to prevent competition law violations before they occur and clarify basic items that must be observed when executing business duties. These regulations specify the establishment of a Competition Law Compliance External Reporting Hotline for reporting and consultation, the implementation of regular auditing by the Auditing Department related to competition law compliance, pre-approval and post-reporting procedures for the prevention and monitoring of contact with competitors to implement supervision and guidance of the status of compliance with competition laws. Furthermore, Furthermore, we are holding competition law compliance workshops mainly for sales divisions to ensure thorough compliance with competition laws in the workplace. These workshops provide detailed explanations of competition law compliance regulations, as well as numerous case studies taken from real incidents presented by lawyers. These activities have also been rolled out to production and overseas worksites in an effort to ensure thorough compliance and strengthen the Group-wide competition law compliance structure.