Compliance

Basic Approach

The MinebeaMitsumi Group believes that implementing compliance is an essential part of promoting CSR. Accordingly, we have established the MinebeaMitsumi Group Code of Conduct and MinebeaMitsumi Group Officer and Employee Compliance Guidelines, and on the basis of these policies, we strive to achieve fair, appropriate and highly transparent management.

Please refer here for detailed information regarding the MinebeaMitsumi Group Code of Conduct and MinebeaMitsumi Group Officer and Employee Compliance Guidelines.

Compliance Promotion Structure

image : Compliance FrameworkThe President and Chief Executive Officer of the MinebeaMitsumi Group has ultimate responsibility for compliance. He is supported directly by the Compliance Committee. Meeting twice a year, the committee ensures implementation of the Code of Conduct and makes decisions on emergency response measures in the event of significant violations of the code. In FY2017, we investigated responses taking into consideration the most recent versions of laws and regulations and other factors as well as reinforcement of Group structures.

The Compliance Promotion Office acts as the administrative body for the Compliance Committee, creating various policies for the promotion of compliance. In Thailand, a Compliance Committee was established in FY2016, and efforts are being made to gather information on issues and respond to them.

Compliance Awareness Survey

MinebeaMitsumi conducts compliance awareness surveys biennially to gauge Group employees' understanding of compliance.

Based on the results of the survey, which was conducted in October and November 2017, we confirmed that there are no problems regarding awareness and interest regarding compliance. Feedback on the survey results was provided to individual divisions, and we continue to broadly disseminate information on how to use consultations services, which was identified as an issue.

Compliance Education

image : Employees receive training

Employees receive training

The MinebeaMitsumi Group also provides training to deepen employees' understanding of compliance. Compliance training is provided along with rank-based training programs. In FY2017, 159 employees received training. We also provide lectures in and outside Japan as part of regular training on compliance with Japan's Antimonopoly Act (competition law). Lectures were given to 541 employees in Japan and overseas.

Overseas, we conducted compliance training for Japanese employees in Thailand, our largest production site. The training was attended by 178 employees.

Internal Reporting System

The MinebeaMitsumi Group provides internal and external consultation services for employees to contact when they have questions about whether their own conduct violates the MinebeaMitsumi Group Code of Conduct, or in cases where employees believe others may be in violation of the code and it is possible to make an anonymous report.
The audit & supervisory board members are also independently taking part in the internal reporting consultation services.
We stipulate the prohibition of disadvantageous treatment of the reporter due to such consultation in the MinebeaMitsumi Group Code of Conduct and ensure to have a structure to protect personal information and confidentiality.

Freight and Compliance Management in Logistics

The Logistics Division is primarily in charge of import and export matters for the MinebeaMitsumi Group. The division creates procedural manuals and guides for adhering to the Customs Law and other regulations and provides a management structure to ensure compliance. In FY2007, we received Authorized Importer and Authorized Exporter certification from Tokyo Customs in recognition of our outstanding freight and compliance management. Also, in FY2017, preparations and applications for attainment were carried out in Malaysia and Europe.

Anti-Corruption/Anti-Bribery Rules

The MinebeaMitsumi Group participates in the UN Global Compact that incorporates the ten principles in the four areas of human rights, labour, environment and anti-corruption. By clearly expressing top management's intention on anti-corruption/anti-bribery both inside and outside the company, the Group has established the "Anti-Corruption/Anti-Bribery Rules" in order to have all officers and employees endeavor to prevent any corruption/bribery (including small payments such as facilitation payments) from occurring at any country or territory. Additionally, the Group has established the "MinebeaMitsumi Group CSR Procurement Guidelines" in order to prohibit any corruption/bribery of suppliers.

Please see the website here for detailed information regarding MinebeaMitsumi Group CSR Procurement Guidelines.

Future Compliance Promotion

The MinebeaMitsumi Group believes that employee awareness and knowledge of compliance should be deepened to establish a corporate culture in which each employee maintains an awareness of compliance in conducting business activities. Moving forward, we will enhance our training programs and thoroughly raise awareness of consultation centers, to strengthen collaboration among countries to improve our compliance structure covering the entire MinebeaMitsumi Group.

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