Governance Anti-Corruption

Policy and Basic Mindset

The UBE Group stipulates in the UBE Group Action Guidelines that it acts in compliance with social norms and maintains a sound and normal relationship with political entities and administrations and has put in place anti-bribery guidelines to prevent corruption, including the bribery of public servants in and outside of Japan.

UBE Group Policy on Bribery Prevention

The UBE Group will not engage with any person in any act of bribery such as the provision and acceptance of improper benefits in terms of the importance of bribery prevention for domestic and foreign public officers and other related individuals or entities.

(1) Prohibition of bribery

Personnel of the UBE Group will not engage in the provision, acceptance or promises of any demands for money or other undue favors, and the proposal or authorization of the provision or acceptance of them to or from public officers or other related individuals or entities, with the intention of obtaining improper benefits in domestic and foreign businesses.

(2) Development of a bribery prevention framework

The UBE Group will develop whistleblowing system and audit system in a fair and equitable manner, and will maintain and operate the appropriate framework designed to prevent acts of bribery.

(3) Recording of transaction detail

The UBE Group will accurately and properly record accounting books and go through accounting procedures in order to prevent acts of bribery and ensure the early detection of them.

(4) Implementation of Education

The UBE Group will continually implement education and training to its personnel in order to maintain and improve the ethical mindset for preventing bribery.

• “Public officers and other related individuals and entities” includes any of the following persons or entities:
• • A person engaged in public duties for the national or local governments in Japan or other countries,
  • A person engaged in the affairs of the national or local governments in Japan or other countries,
  • A person engaged in public duties for a public body,
  • A political party or a staff member,
  • A person engaged in public duties for an international organization,
  • A person authorized by foreign government or public body, and
  • Any other person similar to any of them above.

Management System

The management system is the same as our compliance promotion system.

Targets and Performance

Disciplinary Actions Taken Against Corrupt Practices

There were no cases of disciplinary action taken against corrupt practices in fiscal 2023, and there were no penalties or fines levied against such acts.

Initiatives

Main Initiatives

The UBE Group has stipulated matters related to anti-corruption in the UBE Group Action Guidelines and the UBE Group Bribery Prevention Policy, and, through the use of a self-check system as well as audits and other measures taken by internal auditing departments, the Group regularly monitors the status of its adherence to anti-corruption principles.

The Compliance Committee and Compliance Officers jointly operate a structure for securing robust compliance that is monitored by the Board of Directors, with the Strategic Management Meeting (Sustainability Committee) providing them with direct supervision and instructions. Based on this structure, we strive to prevent corruption throughout the entire supply chain and, to this end, conduct training through e-Learning and other methods for officers and employees. We have also established hotlines for business partners and the internal reporting system “UBE C-Line,” both of which enable us to accommodate reports and requests for consultation on relevant matters. When such reporting results in cases involving the suspicion of bribery of public officials, excess hospitality toward business partners, receipt of money or goods, collusion, or other such acts of corruption, Compliance Officers and relevant departments act to quickly assess the truth of such matters and take measures as necessary.

UBE has signed the UN Global Compact, and has pledged to uphold the anti-corruption principle. The Company is also a member of the Global Compact Network Japan.

Employee Education

The UBE Group conducts the following employee anti-corruption education.

• Regular education via e-Learning for officers and employees (bribery of public officials, collusion with business partners, etc.), group training
• Audits conducted through self-check systems and internal auditing departments