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 identifies important compliance issues by considering the expectations of society, the degree of impact on the company and society, and the frequency of occurrence. The issues identified are addressed as priorities.
A variety of approaches are undertaken to implement the Charter of Corporate Behavior.
Implementing the corruption prevention measures required for global business transactions
Along with economic globalization, the need for anti-corruption measures has increased, and relevant regulations are being strengthened not only within individual countries, 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 extorting or accepting bribes, and a ban on any contact with organized criminal elements. In fiscal 2016, preventing corruption was designated as a Konica Minolta group-wide priority issue in the Group’s annual compliance promotion plan. In cooperation with the regional compliance coordinators, the Group compliance support office provided anti-corruption education to relevant employees at Konica Minolta, Inc. and its subsidiaries worldwide, in line with the laws and practices in the countries concerned. 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 anti-corruption education, as well as anti-corruption issues and risks.
So far, the principle efforts included the issue of an Anti-Corruption, Anti-Bribery Policy document at the North American office equipment and business solutions sales company, education on commercial bribery in China, seminars on responding to transparency guidelines in the healthcare industry (in Japan), and trainings on anti-corruption laws for staff with responsibility for transactions in China and the U.S (in Japan).
Moreover, in China, specific guidelines on gifts and entertainment were added as a guide to prevent corruption in the Compliance Manual for China. In 2016, the company issued anti-corruption guidelines for employees in Japan, which specifically indicate what kinds of gifts and entertainment would violate the Charter of Corporate Behavior. Konica Minolta will continue to share best practices from initiatives at each company and promote practical anti-corruption measures in line with the relevant laws in each country, exemplified by the US Foreign Corrupt Practices Act, the UK Bribery Act, and China’s Law Against Unfair Competition.
There were no incidents regarding bribery or corruption in fiscal 2016.
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 been designated as a Konica Minolta group-wide priority in the Group’s fiscal 2016 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.
So far, the principle initiatives included awareness raising about antitrust laws in education programs for employees at each level, education for company presidents and sales department general managers in Europe, and education about the Subcontract Act, which is a complementary law of the Antimonopoly Act, for production departments in Japan.
In fiscal 2016, there were no problems related to antitrust laws.
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. Japan's Foreign Exchange and Foreign Trade Control Law regulates the trade not only of weapons, but also of goods and technology that could be used to create weapons. When exporting goods, such as products or parts, or technology, 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).
To meet such requirements, the Konica Minolta Inc. has established its own Export Control Code for Security Purposes, and has created an export control system. To implement them strictly, in addition to careful technical classification and transaction screening, Konica Minolta Inc. conducts training of employees and internal audits on export control.
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 2016, there were no infractions of the Act against Unjustifiable Premiums and Misleading Representations.