Compliance Promotion System
Group Compliance Promotion System
Building a system to promote consistent compliance Group-wide
At Konica Minolta, the Chief Compliance Officer, a person 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 Business Units and Corporate Divisions 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.
Note: An executive officer or a corporate vice president plays the role of Chief Compliance Officer.
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 each department and subsidiary with its activities, directly and indirectly, and provides support for group-wide information management.
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 2020, 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.
Planning Compliance Promotion and Verifying Progress
All departments at Konica Minolta, Inc. and all of its Group companies are required to carry out compliance according to a group compliance promotion plan and report their progress.
Konica Minolta identifies material issues by looking at trends in social expectations and the results of compliance risk assessments, and prepares a medium-term compliance promotion plan. Furthermore, based on the medium-term plan, a group compliance promotion plan is prepared for each fiscal year, and each department and group company is required to implement measures accordingly. In fiscal 2020, each department, including subsidiaries under their management, formulated their own plans and implemented measures that take into consideration compliance risks in their respective business domains.
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 progress of their measures, as well as any compliance issues 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. When a compliance issue arises which may cause a violation against Konica Minolta Group Charter of Corporate Behavior, it must be reported to the Chief Compliance Officer immediately.
Based on these reports submitted to the Chief Compliance Officer, the Group compliance support office and regional compliance coordinators cooperate as needed to conduct activities Group-wide. Any remaining issues are reflected in the plan for the following year.
The Corporate Audit Division, which reports directly to the President & CEO, conducts internal audits of Konica Minolta, Inc. and its worldwide subsidiaries. The audits also look at compliance, and detailed checks are made to ensure that measures are being implemented according to the annual plans of target group companies, and to confirm that the system to ensure thorough compliance is functioning properly. When an issue is identified, a corrective plan is prepared and implemented with the assistance of the Group compliance support office and the relevant regional compliance coordinator.
Progress is then verified through follow-up audits.
There were no significant violations involving bribe, fraud, embezzlement, or any other area of the Konica Minolta Group Charter of Corporate Behavior which warrant disclosure in fiscal 2020.
Internal Hotline Systems (Helpline)
Building and improving hotlines at each Group company
In the Konica Minolta Group in Japan, the Group-wide helpline is available so that employees can use it to seek consultation and directly contact the general manager of the Legal Division, the persons in charge of helpline, 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.
This external helpline was expanded to include outside suppliers in Japan beginning in November 2020.
Konica Minolta was recognized as appropriately setting up and running an internal helpline system, and in fiscal 2019 its designation as one of the registered businesses for declaration of conformity with the whistleblowing compliance management system certification (declaration of conformity registration system) under the jurisdiction of the Japan’s Consumer Affairs Agency was renewed.
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 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). Konica Minolta Business Solutions Asia Pte. Ltd. in Singapore established internal hotlines for Group companies in Southeast Asia. In addition, measures to raise awareness of internal hotline systems were taken again at subsidiaries in and outside Japan, in order to increase their accessibility.
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. Each report made is examined fairly, equitably and with integrity to determine the need for an investigation. The whistleblower is notified of the response, and the information received through this internal report is only shared with those involved in the investigation and managed so that the whistleblower does not suffer any disadvantages.
The content of a hotline report in each case is kept confidential and investigated in detail. In the event of a compliance issue, the main department for the hotline system works in cooperation with the relevant departments to correct the problem and prevent any recurrence. The Chief Compliance Officer reports information on the records of the internal hotline systems to the Audit Committee regularly.
In fiscal 2020, there were 14 reports to the internal hotlines in Japan and 44 reports to the overseas hotlines. Eight of these reports in Japan and 21 of these overseas were regarding human rights issues (power harassment/sexual harassment/discrimination/improper treatment).
There were no significant incidents reported from these internal hotlines that warrant disclosure either inside or outside Japan in fiscal 2020.