Putting Compliance into Practice
Practicing Compliance Based on the Charter of Corporate Behavior
Based on the Konica Minolta Group Charter of Corporate Behavior, the company conducts a comprehensive risk assessment every six months to identify compliance-related risks such as corruption (bribery, improper payoffs, conflicts of interest, etc.), antitrust law violations (private monopoly, unfair trade practices, unfair restraint of trade, etc.), and violations of the Act on the Protection of Personal Information. These risks are reported to the Risk Management Committee, and are then identified as important compliance issues. Then the issues identified are addressed as priorities.
Implementing global anti-corruption measures focusing on areas with high corruption risk
Along with economic globalization, the need for anti-corruption measures has increased, and relevant regulations are being strengthened not only within Japan, but also for international commercial transactions. The guidelines for preventing corruption are set forth under Section 2, “Fair and Transparent Corporate Activities,” in the Konica Minolta Group Guidance for the Charter of Corporate Behavior. They include a prohibition on extorting gifts and entertainment, a prohibition on soliciting or accepting bribes, and a ban on any contact with organized criminal elements.
Every year, the Konica Minolta Group prioritizes compliance with antitrust laws and preventing corruption in its annually renewed compliance promotion plan, considering the expectations of society, the degree of impact on the company and society and the possibility of occurrence. In fiscal 2019, the Group used a worldwide compliance promotion system to continue to educate its personnel on these two priority issues, in line with the relevant laws, business environments, and customary practices. The compliance issues, risks, and progress of education in each region are regularly reported to the Chief Compliance Officer via compliance reports. In fiscal 2018, the anti-corruption guidelines for personnel in Japan were revised in response to changes in public expectations, and efforts were made to ensure that the new guidelines are thoroughly understood. In fiscal 2019, new guidelines were prepared for personnel in other countries and regions as well, in accordance with their respective laws and cultures, and expanded to worldwide.
As part of the company's comprehensive anti-corruption efforts, in fiscal 2019 standards and rules were created concerning the provision of gifts and entertainment to clients. They were prepared by referring to the country rankings in the annual Corruption Perceptions Index (CPI) reported by Transparency International (TI), and are applicable to Konica Minolta organizations operating in countries where the risk of corruption is high. Systems for accounting monitoring and checking have also been established and deployed at each subsidiary, and reports are sent every quarter to the compliance department.
There were no incidents regarding bribery or corruption in fiscal 2019.
Compliance with Antitrust Laws
Formulating antitrust law policy and undertaking education in accordance with the laws and business environment in each region
Konica Minolta recognizes that when violations of an antitrust law occur, the impact on companies, the economy and society is extremely serious. Section 2, "Fair and Transparent Corporate Activities," in the Konica Minolta Group Guidance for the Charter of Corporate Behavior stipulates requirements for compliance with antitrust laws in relevant countries and regions, and for fairness and transparency in transactions between companies. Antitrust law measures have again been designated as a Konica Minolta group-wide priority in the Group's fiscal 2019 compliance promotion plan. The Group compliance support office and the regional compliance coordinators have taken the lead in providing education to relevant employees at Konica Minolta, Inc. and its subsidiaries worldwide, in line with the laws and business environment in each region.
This initiative will be continued in the future. Reports on the progress of compliance promotion are regularly submitted to the Chief Compliance Officer, including the status of education on antitrust law measures, as well as antitrust law issues and risks.
In fiscal 2019, it is suspected that there was 1 violation of antitrust law, as indicated by authorities outside Japan. The company is currently investigating the details to address this issue.
Export Control for International Peace and Security
Practicing strict export control to maintain international peace and security
Today there is heightened concern over the proliferation of weapons of mass destruction and terrorist attacks. Accordingly, as a member of the international community, the government of Japan participates in international treaties and regimes such as the Nuclear Nonproliferation Treaty and the Wassenaar Arrangement and has reflected their rules to be observed in Japan's Foreign Exchange and Foreign Trade Control Law. This law regulates the trade not only of weapons, but also of goods and technology that could be used to produce weapons. It specifies that companies are required: (1) to determine whether or not it is an advanced technology or goods that could be used for weaponry as listed under international agreements (technical classification); and (2) to check the users and the intended use for any risk of its being used for the development or manufacture of weapons of mass destruction (transaction screening).
Konica Minolta has established an Export Control Code for Security Purposes and created an export control system in group companies in Japan, and it carries out strict technical classification of products and transaction screening to ensure adherence to the Foreign Exchange and Foreign Trade Control Law. In addition, Konica Minolta systematically provides security export control training to employees and conducts internal audits on security export control operations.
Konica Minolta has established a group-wide tax policy.
The Konica Minolta Group Tax Policy has been established in order to contribute to the development of local communities by ensuring that we properly fulfill the duty to pay taxes related to our business operations.
Konica Minolta has established the Konica Minolta Group Charter of Corporate Behavior as its global standard for the disclosure of useful and reliable information.
In its advertising, Konica Minolta gives first priority to compliance with the relevant laws and industrial regulations in each region of the world. Beyond the basic laws, the company endeavors to conduct fair and proper advertising, taking into account the voluntary restrictions and advertising standards that apply in each of its business fields, as well as respecting public morality and the viewpoints of stakeholders.
For example, laws and standards that the company observes in Japan include regulations governing advertisements such as the Act against Unjustifiable Premiums and Misleading Representations, the Standards for the Representation of Copiers and Multi-Function Printers of the Japan Business Machine and Information System Industries Association, the Code of Ethical Practice of the Japan Advertisers Association, and screening standards for various media.
In fiscal 2019, there were no infractions of the Act against Unjustifiable Premiums and Misleading Representations.