Compliance Promotion System
Group Compliance Promotion System
Building a system to promote consistent compliance Group-wide
At Konica Minolta, the Chief Compliance Officer, who is appointed by the Board of Directors, determines important matters for the promotion of the Group’s compliance and is responsible for promoting and overseeing compliance activities such as anti-corruption measures and personal information protection. The Chief Compliance Officer reports directly to the President and CEO of Konica Minolta, Inc., who has ultimate responsibility for Group compliance. To fulfill that responsibility, the Chief Compliance Officer convenes the Group Compliance Committee, which is composed of officers responsible for compliance from corporate departments in charge of Group-wide functions.
To promote compliance in each department at Konica Minolta, Inc., the General Manager of each department serves as the official responsible for compliance; at subsidiaries inside and outside Japan, the president of each subsidiary serves as the official responsible for promoting compliance at each company. The Chief Compliance Officer reports regularly to the Audit Committee regarding the progress of compliance activities and important compliance issues in the Group.
Group Compliance Promotion System
Global Group Support System
Strengthening the coordination of Group compliance
The Legal Division at Konica Minolta, Inc. drafts plans to address important matters and measures regarding the promotion of the Group’s compliance, serving as a Group compliance support office assisting the Chief Compliance Officer. The Legal Division also assists with the compliance activities of each department and subsidiary, directly and indirectly, and provides support for the Group-wide coordination of information.
The Chief Compliance Officer also appoints regional compliance coordinators in Europe, North America, China, and Southeast Asia, tasking them with implementing activities to promote compliance, considering the circumstances of each region.
In fiscal 2016, the Group compliance support office and regional compliance coordinators worked together to help newly acquired companies inside and outside Japan as well as small Group companies to adopt compliance measures, seeking to instill compliance throughout the entire Konica Minolta Group.
Confirming Compliance Progress
Each department in Konica Minolta, Inc. and its Group companies is required to report progress on promoting compliance
In order to ensure thorough compliance awareness at Group companies inside and outside Japan, each company is required to report regularly on the status of compliance.
The officials responsible for compliance in each department at Konica Minolta, Inc., and at each Group company inside Japan are required to submit monthly reports on the status of the promotion of compliance and the implementation of compliance activities, and significant compliance risks in that department or company to the Chief Compliance Officer. The officials responsible for compliance at each Group company outside Japan must do likewise on a quarterly basis.
Based on these reports submitted to the Chief Compliance Officer, the Group compliance support office and regional compliance coordinators cooperate as needed to facilitate activities that support the promotion of compliance Group-wide.
There were no significant incidents regarding compliance that warrant disclosure in fiscal 2016.
Internal Hotline Systems(Helpline)
Building and improving hotlines at each Group company
Konica Minolta is working on building and improving internal hotlines. In Japan, the Group-wide helpline is available so that employees can use it to seek consultation and directly contact the president, Chief Compliance Officer, general manager of the Legal Division, or an outside lawyer via various channels such as telephone and email, when they become aware of any conduct that poses a risk of non-compliance. In fiscal 2016, the internal hotlines in Japan received 31 reports (four of these to the outside lawyer).
Konica Minolta has also established internal hotlines outside Japan. Konica Minolta Business Solutions U.S.A., Inc., an office equipment and solutions sales company in the U.S., has a Whistleblower’s Hotline, which has served as an internal reporting system for its employees in North America, including its subsidiaries in Canada and Mexico. In Europe, the Integrity Hotline has served as a 24-hour, multi-lingual reporting system for all Group employees in Europe. Furthermore, the Group expanded its internal hotline systems in 2015. In China, an internal hotline system using an outside lawyer as a receiver of reports was established for all Group companies in China (excluding companies in Hong Kong). An internal hotline for Group companies in Southeast Asia was also established at Konica Minolta Business Solutions Asia Pte. Ltd. in Singapore, seeking to further enhance the helpline system in 2015.
In fiscal 2016, there were 27 reports to these overseas hotlines.
These hotlines can be contacted and consulted anonymously. In addition, the whistleblowers do not suffer any negative repercussions for having contacted or consulted the hotlines.
The content of a hotline report in each case is investigated in detail, and instructions are given to concerned departments for immediate improvements, taking care to ensure that whistleblowers suffer no negative repercussions. The Chief Compliance Officer reports information on the records of the internal hotline systems to the Audit Committee regularly.
There were no significant incidents reported from these internal hotlines that warrant disclosure either inside or outside Japan in fiscal 2016.