EBARA Corporation and its consolidated subsidiaries and affiliate companies (hereafter, the Group) will strive to prevent corruption by taking voluntary measures in order to promote the sound development of business activities.
All directors, executives, and employees (members) of the Group shall be aware of and strive to promote anti-corruption in the course of their business, comply with relevant laws and regulations and conduct themselves in accordance with relevant internal regulations and the anti-corruption program.
As part of its internal control system, the Group shall establish and properly operate an anti-corruption program consisting of not only the implementation of anti-corruption rules, but also compliance consultation hotlines and internal training sessions. In the event that any of its members commit an act of corruption, the Group shall promptly take action to correct the situation and, if necessary, modify the content of the anti-corruption program to prevent recurrence.
The contents of this policy and program are communicated to all employees of the Group.
The EBARA Group has implemented an anti-corruption program aimed at encouraging free and fair competition, the rejection of any relations with antisocial forces, and prohibition of bribery. This program is applied to all companies in the Group and consists of 5 parts:
A declaration made by the top executive of each group company forbidding any corrupt acts or practices by employees or the company
The approval of each company's Board of Directors of the Anti-Corruption Basic Policy
The implementation of internal regulations prohibiting any acts of corruption
The establishment of whistle-blowing hotlines that allow employees to anonymously blow the whistle on any activity that may be in violation of the policy or internal regulations
The dissemination of 1-4 to all employees
The internal regulations define acts of corruption beyond simply bribery and also offer limitations on various types of expenses and the giving of benefits including: entertainment, gifts, travel, political or charitable donations, facilitation payments, and third-party commission fees.
The EBARA Group takes disciplinary action against those who violate the anti-corruption regulations in place.
The Sustainability Committee, chaired by all executive officers and attended by members of the Board of Directors, receives reports on the status of the regulations and whistle-blowing hotlines. The Sustainability Committee reports its deliberations to the Board of Directors and the Board conducts appropriate oversight.
President and Representative Executive Officer
March 28, 2019
(English translation of original Japanese document)
Since 2012 the EBARA Group's Anti-Corruption Program has been one of the core elements of our CSR activities. It has an important role in the implementation of our business ethics. The Program consists of 3 elements: namely, prohibition of the taking and receiving of bribes, promotion of fair and free competition, and exclusion of any ties with anti-social forces. Today, with the global expansion of the Program, we continue to monitor, evaluate, and adjust ourselves, always keeping the same original commitment against corruption.
As the President and Representative Executive Office of EBARA Corporation, I hereby renew our pledge against corruption.
The Group’s management and employees will promote fair, faithful, and transparent business activities by complying with all laws and ordinances, as well as relevant internal policies and rules.
The Group will not tolerate breach of laws, ordinances, or internal policies and rules by our management and employees. Infractions will be met with strict consequences. In the event of a clear incident of corruption, the Group will suspend its business transaction with the offending external party.
Top management will take initiative in implementation of the Anti-Corruption Program by actively disseminating the Program and leading by example. Top management will also take responsibility when there is suspicion of corruption by ensuring proper measures are taken in the course of investigations and taking measures to prevent any recurrence.
The Group recognizes that trust and confidence gained from other companies, customers, business partners and stakeholders is indispensable and strives to gain that through fair, faithful and transparent business activities.
The Group will aim at thorough prevention of corruption, by periodically providing internal training sessions, reexamining regulations, and reviewing the state of compliance, in accordance with the Anti-Corruption Program.
EBARA Group implemented the Anti-Corruption Program at domestic subsidiaries in fiscal 2012 and overseas subsidiaries in fiscal 2013, and has been operating the Program since then. Every year, we review our global Anti-Corruption Program with reference to the Corruption Perceptions Index published by Transparency International, to identify high-risk areas we conduct business in. At the same time, we monitor the latest information on anti-corruption legislation in each country and update our company rules and regulations in a timely manner to reflect the most recent laws and regulations.
Additionally, we conduct training for employees in higher-risk functions such as sales, etc.
We have established multiple reporting channels to ensure that employees and others who work with the Group feel comfortable voicing questions and concerns about bribery or other potential corrupt practices.
One such channel is the compliance liaisons assigned to workplaces to establish an environment where employees feel free to consult regarding compliance-related matters. Compliance Liaisons are located at every EBARA Corporation site and some domestic subsidiaries.
The Group’s CSR Procurement Guidelines include a list of items we expect our suppliers to cooperate with. This includes a part regarding corruption prevention, including obtrusion and bribery. (9. Corruption Prevention)
In fiscal 2022, we conducted a CSR Procurement Questionnaire to check the level of awareness of these guidelines among our suppliers and the status of their CSR efforts. We will continue to work together with suppliers who need to improve through direct dialogue and visits.
For more information see our Supply Chain Management page.
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