Governance Compliance

Policy and Basic Mindset

UBE Group Compliance Guidelines

The UBE Group is committed to ensuring compliance in the execution of its corporate activities and business, in accordance with laws and regulations in and outside of Japan, internal regulations, and social norms and rules. Through the integrity of its actions, it will live up to the expectations of society.

The UBE Group operates compliance-based business on the following pillars.

1. Establishment of UBE Group Code of Conduct

The UBE Group established the Action Guidelines, in order to ensure that officers and employees conduct business in accordance with laws and regulations in and outside of Japan, internal regulations, and social conscience. We revise the guidelines as needed to meet shifting social expectations of corporations and distribute booklets featuring the latest version of the guidelines, our compliance structure, internal reporting systems, and other relevant matters, to officers and employees to infuse compliance throughout the Group.

2. Preparation of Framework for Securing and Practicing Compliance

UBE appoints Compliance Officers who are responsible for overseeing tasks related to ensuring and practicing compliance at the UBE Group. The Compliance Officers receive advice from the UBE Group Compliance Committee, and supervise and manage compliance frameworks for each department and Group company. Under the Compliance Officers’ direction, the compliance frameworks are securing and practicing compliance through education and training, rapid correction of compliance issues, and the adoption and execution of recurrence prevention measures through continuous monitoring.

3. Internal Reporting System

The UBE Group internal reporting system (UBE C-Line) enables employees to report compliance violations directly to the Compliance Promotion Secretariat, to facilitate the rapid identification and resolution of compliance issues of the Group.

Basic Policy for Anti-Social Forces

The UBE Group is firm in its response against groups or individuals comprising anti-social forces (organized crime groups) that pursue economic profit with violence, coercion or fraudulent measures, and rejects all relation to such forces. Exercising caution that funds are not used in money laundering or to benefit terrorist groups, we have designated the following basic policies and created a system toward such ends.

  • We do not maintain relations of any kind or conduct transactions with anti-social forces.
  • We refuse to meet the demands of anti-social forces, and will pursue legal avenues against such demands through civil courts and criminal justice.
  • Under no circumstances will we pay money to or cover up transactions with anti-social forces.
  • We will work closely with external organizations, including police authorities, the National Center for Removal of Criminal Organizations, and attorneys, to protect against anti-social forces.
  • We will maintain a unified corporate front in the face of demands from anti-social forces in order to protect the safety of our officers and employees.

UBE Group Code of Conduct

Management System

Compliance Promotion System

The Compliance System is as follows.

The Compliance Officers (executive officers) are responsible for overseeing compliance at the UBE Group and advised by the Compliance Committee. Compliance Facilitators are assigned for each department and Group company to ensure that compliance is practiced and resolve compliance issues in cooperation with the Compliance Promotion Secretariat.

The Compliance Committee is one of the working committees dealing with internal control of the UBE Group, and Compliance Officers regularly report on compliance issues and situations to the Strategic Management Meeting (Sustainability Committee) and the Board of Directors, receiving monitoring and direction on initiatives.

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Targets and Performance

Targets

In accordance with the UBE Group Compliance Policy and our Action Guidelines, we are proceeding with the following initiatives.

Targets Frequency Dates Held in Previous Fiscal Year Dates Held in Subsequent Fiscal Year (Planned)
Regular meetings of the Compliance Committee Quarterly Quarterly (fiscal 2023) Quarterly (fiscal 2024)
Annual reports to the Board of Directors and the Strategic Management Meeting Annually April 2024 Fiscal 2025
Compliance e-Learning for all employees Twice annually Twice in fiscal 2023 Twice in fiscal 2024
Meetings of liaison groups regarding the Act Against the Delay in Payment of Subcontract Proceeds, Etc., to Subcontractors Twice annually October 2023 October 2024
Training on relevant laws and regulations (Antimonopoly Act; Act Against the Delay in Payment of Subcontract Proceeds, Etc., to Subcontractors; etc.) More than once annually Twice in fiscal 2023 Twice in fiscal 2024
Compliance awareness survey for all employees Once every four years October 2023 Fiscal 2027

Number of the internal reports

(related to harassment)
FY2018 FY2019 FY2020 FY2021 FY2022 FY2023
32 (14) 22 (13) 25 (16) 34 (16) 35 (18) 25 (13)

Initiatives

Compliance with Competition Law

The Competition Law Compliance Committee operates within the UBE Group Compliance Committee to ensure that corporate activities are soundly executed and do not prevent fair and free competition in markets. It establishes a framework to prevent against cartels and monopolies, in accordance with competition laws (anti-monopoly laws) in and outside of Japan. For example, if conducting a sales meeting with a same industry competitor, rules are in place that require prior approval from the managing department and the filing of a follow-up report in order to prevent a cartel and address the root of the problem.

Compliance with Export Laws and Regulations

The UBE Group implements export controls to prevent the unauthorized export or supply of restricted goods and technologies, in accordance with the Foreign Exchange and Foreign Trade Act and other legislation intended to maintain peace and security in Japan and the international community. The Group operates the Security Export Control Committee, which works to ensure that Group companies are fully aware of the restrictions.

Political Contributions

As stipulated in the Political Funds Control Act, the UBE Group donates political funds only if such donation is approved as prescribed in its internal rules.

Expenditures for Political Contributions in FY2023 ¥800,000

Internal Reporting System (UBE C-Line)

The UBE Group internal reporting system (UBE C-Line) enables employees* to directly report suspected or confirmed compliance issues (human rights infringements (e.g., bullying, harassment, discrimination and labor issues), corruption (e.g., bribery, excessive entertainment and adhesion), fraud (e.g., fictitious claims and embezzlement), falsification of product data, and other illegal activities) within the UBE Group. Employees are enabled to report anonymously and protected from retaliation by internal regulations.

When a compliance case is opened, the Compliance Promotion Secretariat cooperates with the organization concerned and investigates the matter in order to arrive at a resolution involving disciplinary actions and corrections as warranted. We post some cases such as harassment in the workplace on the intranet as appropriate, and strive to prevent recurrence by sharing information and calling attention to incidents.

  • *Encompasses officers and employees of Group companies as well as the officers and employees of subcontractors.

Reporting Hotlines for Suppliers, etc.

The UBE Group is committed to ensuring compliance in the execution of its corporate activities and business, in accordance with laws and regulations in and outside of Japan, internal regulations, and social norms and rules.

If you recognize any compliance violation, including potential or alleged cases of such violations, in connection with the UBE Group’s business activities, please inform this to us using the following form.

This is a dedicated form for reports submitted by external individuals, such as suppliers. Please use the “Inquiries” page when communicating your opinions to or seeking consultation with the UBE Group.

  • Note:Applicable cases of compliance violations include acts of harassment, violations of human rights, acts of corruption such as bribes (both provision and acceptance) or collusion, such acts of misconduct as false billing and embezzlement, and the falsification of product or other data as well as other forms of illegal conduct.

Employee Training

The UBE Group conducts compliance education mainly as follows.

  • Grade-specific compliance training (new employees, new managers, etc.)
  • Training on compliance toward relevant laws and regulations (Antimonopoly Act; Act Against the Delay in Payment of Subcontract Proceeds, Etc., to Subcontractors; Unfair Competition Prevention Act, etc.)
  • Compliance e-Learning for all employees: Twice annually (harassment; accounting fraud; competition law; Act Against the Delay in Payment of Subcontract Proceeds, Etc., to Subcontractors; quality fraud; etc.)
  • Distribution of UBE Group Code of Conduct booklets
  • Compliance Promotion Month and messages from the CCO (every October)
  • Compliance awareness surveys
  • Posters with compliance slogans and other features designed to instill compliance awareness
  • Spreading awareness of our internal reporting system