The Nissui Group is working to enforce compliance in a thoroughgoing manner including complying with laws and regulations in/outside Japan as well as various internal rules pursuant to the Code of Ethics, in order to meet the expectations of all of its stakeholders such as customers, employees, business partners and shareholders and fulfill its corporate responsibility. Having established the "Ethics Subcommittee" under the Risk Management Committee, we are endeavoring to implement measures for the early detection, rectification and recurrence prevention of compliance issues and striving to raise employees' awareness of compliance. We are also engaged in initiatives to develop and enhance the compliance structure of the Nissui Group as a whole, not just Nissui Corporation.
The Ethics Subcommittee is set up under the umbrella of the Business Foundation Risks Committee with the aim of enhancing compliance in Nissui as well as its Group companies in Japan. The Ethics Subcommittee is convened once every two months (i.e., six times a year) and the extraordinary meeting is held as necessary. In addition, the participation of outside attorney ensures its objectivity.
In fiscal 2023, the Ethics Subcommittee was convened 8 times in total, where whistleblowing response, compliance activity plans, compliance questionnaire surveys, etc., were deliberated.
![[Figure] Promotion Framework - The Risk Management Committee](/assets/img/common/risk_img-01e.svg)
We have a whistleblowing system in place, enabling employees of Nissui and its Group companies in Japan to directly notify the Ethics Subcommittee with regard to harassment, labor issues and acts of questionable compliance, including corruption and bribery in the workplace. We have established points of contact for whistleblowing both internally (i.e., the Legal Department serving as the secretariat of the Ethics Subcommittee) and externally (i.e., outside specialist), and have a mechanism whereby the Audit & Supervisory Board Members are also contacted simultaneously. Whistleblowing notices are given directly by such means as telephone, Web and email, and may be made anonymously.
In the event that a whistleblowing notice has been given, the Ethics Subcommittee conducts an investigation by selecting a person responsible for the investigation while giving consideration to ensure that the whistleblower will not be put at a disadvantage, and examines the findings of the investigation and improvement measures within the Subcommittee.
When conducting an investigation, there is a clear policy "not to look for the whistleblower," and the protection of confidentiality and the prohibition of disadvantageous treatment of the whistleblower are stringently enforced. Of note, even if a notice given to the external point of contact for whistleblowing was not anonymous, there is a system in place to report it to Nissui anonymously upon the whistleblower's request. For harassment incidents, multiple points of contact have been established, and such incidents are handled by the Harassment Desk (Human Resources Department). The Harassment Desk also collaborates in conducting investigations into notices given via the points of contact for whistleblowing.
In regards to the minutes of the Ethics Subcommittee including the nature of and response to notices, we have a system in place for the minutes to be reported to and made available for perusal by Directors, Audit & Supervisory Board Members and Executive Officers. Also, the officer in charge makes a report regarding important whistleblowing-related matters to the Board of Directors.
The aforementioned overview of the whistleblower system is stated in Nissui's whistleblowing rules. Of note, in fiscal 2021, the rules were reviewed to prepare for the enforcement of the revised Whistleblower Protection Act.
The operation of the whistleblowing system is described not only on Nissui's internal portal site but also in the "Nissui Group Ethics Card" distributed to Group companies in Japan, to make it widely known among employees.
In fiscal 2023, there were 9 whistleblowing notices related to Nissui and 16 whistleblowing notices related to its Group companies. None of them were whistleblowing notices regarding significant problems that needed to be announced to the public.
| FY2021 | FY2022 | FY2023 | |
|---|---|---|---|
| Total of Nissui Corporation | 18 | 11 | 9 |
| Including harassment/interpersonal relations | 16 | 7 | 7 |
| Including labor problems | 0 | 2 | 0 |
| Other | 2 | 2 | 2 |
| Total of Group companies | 14 | 10 | 16 |
| Including harassment/interpersonal relations | 9 | 5 | 6 |
| Including labor problems | 2 | 2 | 2 |
| Other | 3 | 3 | 8 |
| Sum total | 32 | 21 | 25 |
If a single case involves multiple categories, such as harassment and labor problems, it is counted based on the matter deemed most serious as a problem.
We conduct a compliance questionnaire survey covering employees for the purpose of getting a grasp of company-wide compliance trends, identifying compliance problems in the bud in each organization and making use of the findings to improve the workplace environment in the early stages. The most recent survey conducted in fiscal 2023 covered 2,568 employees (including temporary employees (Note)) of Nissui Corporation, of whom 2,271 employees responded, resulting in a response rate of 88%. For foreign employees, questionnaires translated into five languages (i.e., English, Spanish, Portuguese, Chinese, and Vietnamese) were distributed, to which 316 out of 377 foreigners on Nissui's payroll responded, resulting in a response rate of 84%.
We share the questionnaire survey results with executives and department managers. They use the results as hints for improving the working condition by each organization. And the Ethics Subcommittee discusses the questionnaire survey results and reflects them to actual compliance activities.
| FY2020 | FY2021 | FY2022 | |
|---|---|---|---|
| Number of respondents | 2,073/2,438 persons | 2,183/2,505 persons | 2,271/2,568 persons |
| Ratio of respondents | 85% | 87% | 88% |
Scope: Nissui Corporation (including temporary employees.)
(Note) Temporary employees: Temporary employees including directly-hired contract employees and part-timers.
Once every year, we identify transactions that may put Nissui in a particularly dominant position and conduct a compliance questionnaire survey covering business partners involved in such transactions for the purpose of getting a grasp of whether or not Nissui has engaged in acts of abuse/misconduct (such as violations of the Antimonopoly Act/Subcontract Act) by exploiting its dominant position against its business partners.
The questionnaire survey conducted in fiscal 2023 covered 201 companies, of which 155 companies responded, resulting in a response rate of 77%.
| FY2021 | FY2022 | FY2023 | |
|---|---|---|---|
| Number of respondents | 143/176 companies | 139/176 companies | 155/201 companies |
| Ratio of respondents | 81% | 79% | 77% |
Every year, we conduct compliance training in the form of a mandatory course for new recruits and mid-career hires. For all employees, compliance training is conducted by narrowing down the themes on an irregular basis each time an issue has arisen.
The “Code of Ethics” is posted on Nissui’s internal portal site. The Code of Ethics is shared with employees to raise their awareness of compliance.
In order to reduce compliance risks in the Nissui Group as a whole, Group companies are promoting the development and enhancement of their respective compliance frameworks.
The status of compliance activities at each Group company is periodically reviewed through the Risk Management Committee. On top of this, since fiscal 2020, workshops have been held individually for Group companies, during which the compliance status and issues at each company are shared, and efforts are made to build a higher level of compliance system, such as improving the proper procedures for handling whistleblowing across the entire Group.
