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

The 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.

The Compliance Promotion Office acts as the administrative body for the Compliance Committee, creating various policies for the promotion of compliance. In FY2020, we appointed compliance officers as well as staff and sub-staff in charge of compliance at ABLIC Inc. that was added to the Group as a result of business integration and reinforced structures throughout the Group.

Compliance Framework

image : Compliance Framework

Compliance Awareness Survey

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

Based on the results of the survey, which was conducted in March 2020, 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 are reinforcing training based on the results. We are also broadly disseminating information on how to use consultations services, which was identified as an issue.

We plan to conduct the next survey in FY2021.

Compliance Education

image : Employees receive training

Employees receive training

The MinebeaMitsumi Group provides various training to executives and employees to deepen understandings towards compliance.
In FY2019, we conducted a compliance training including topics of compliance such as prevention of sexual harassment and power harassment taught by outside counsel which was attended by total of 58 employees, including directors, executive officers, and business unit heads. We also conducted compliance training (prevention of sexual harassment, power harassment, etc.) in rank-based training and mid-career recruitment in which 921 employees attended.
For Employees in management positions and above, we conducted training on Prevention of Power Harassment taught by outside instructors which was attended by 325 employees.

In addition, in April 2019, we conducted e-learning-based training to all Japanese employees which included explanations concerning compliance and understanding levels check test.

Internal Reporting System

The MinebeaMitsumi Group has established internal and external consultation services for employees to contact when they have questions about whether their own conduct or decision making violates the MinebeaMitsumi Group Code of Conduct or in cases where employees believe others may be in violation of the code. Anonymous reports may also be made. Reports can also be made internally to corporate auditors.

The MinebeaMitsumi Group Code of Conduct expressly prohibits disadvantageous treatment of an inquiring employee on the grounds that such an inquiry was made, and mechanisms have been put in place to protect personal information and comply with the duty of 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 FY2018, preparations and applications for attainment were carried out in Malaysia.

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. The top management expresses its commitment to anti-corruption/anti-bribery both inside and outside the company.

In order to strengthen the anti-corruption measures at the global level, the Group has established the "Anti-Corruption/Anti-Bribery Rules," which prohibits bribery (including small payments such as facilitation payment, etc.) in all countries and regions in which our business operations are conducted, to prevent corruption/bribery of all officers and employees. In particular, for Asian regions where business practices are complex, the Group has set up the "Standards and Procedures Regarding Provision of Entertainment, Gifts, etc. to Public Officials" and the "Country-By-Country Guidelines for Provision of Entertainment, Gifts, etc. to Public Officials" to ensure through enforcement of the risk management system not to be involved in corruption. These rules have established a system that does not allow officers and employees to engage in entertainment and gifts offering if there is a risk. Additionally, the Group has established the "MinebeaMitsumi Group CSR Procurement Guidelines" in order to prohibit any corruption/bribery of suppliers.

In addition, the Internal Auditing Office conducts periodic checks on the above measures to prevent corruption.

In 2018, no officers or employees committed anti-corruption violations, nor being imposed fines, penalties and settlement money related to corruption.

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 with countries in order to improve our compliance structure covering the entire MinebeaMitsumi Group.

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