Measures to Prevent Harassment
President Message Against Harassment
The EBARA Group strives to act as a good corporate citizen that earns the trust of stakeholders. For this reason, the EBARA Way and the EBARA Group Code of Conduct are shared among all employees to form a common identity and set of values. With this as the foundation, it is our basic policy to practice strict legal compliance, adhere to internal rules and social norms, and act with common sense, good intentions, and integrity.
The EBARA Group's Compliance System
Mandatory harassment training for all EBARA employees
Sharing of compliance-related educational materials on the intranet
Sharing operating results of the Compliance Consultation Hotline internally twice a year
Sharing of compliance educational materials, including those regarding harassment, twice a year with domestic group compliance officers
Implementation of harassment education in the training for newly appointed managers (participants in FY2022: 83 in the Domestic Group)
Assign Compliance Liaison Committee members* (118 as of September 30, 2023) to workplaces nationwide, including domestic subsidiaries, and provide training on compliance, including regarding harassment
Distribute compliance educational materials, including those regarding harassment, monthly to workplaces via Compliance Liaisons
Compliance Liaisons are nominated by each department at EBARA Group companies domestically, and are assigned to workplaces nationwide to act as on-site easily-approachable people to consult regarding compliance concerns or questions. They are also responsible for spreading compliance awareness in the workplace, picking up compliance risks, and early detection and resolution of compliance-related problems.
June 1, 2020
To Everyone in EBARA Group
Masao Asami
President and Representative Executive Officer
EBARA Corporation
Harassment is a violation of human rights, as it injures the dignity of employees and creates hostile work environments. The act of harassment is never acceptable; not within the company between employees, nor to other stakeholders such as to business partners, job seekers to our company, or others.
The EBARA Group is committed to creating a safe and stimulating work environment in which all stakeholders act with respect for one another.
The EBARA Group has established consultation services to resolve issues of harassment and other problems. We will not treat the consulter or anyone who has cooperated in confirming the facts in a disadvantageous manner, and commit to protecting the privacy of those involved.
We will also continue to provide training and educational opportunities for employees. Let’s learn about harassment and strive to create a corporate culture that does not cause or allow harassment.
To all employees of the EBARA Group, let’s work together as one and promise to never commit, allow, excuse, or cover-up harassment. Let’s aim to be a company in which each and every employee can work with pride.
Thank you for your cooperation.
The EBARA Group has established compliance consultation hotlines to create a comfortable workplace and enhance the ability to voluntarily improve internal problems. We have implemented various measures to familiarize employees with their use.
In Japan, each Group company has its own hotline and is in charge of its operations. The Company and Group companies with more than 300 employees have established an internal whistleblower response system in compliance with the revised Whistleblower Protection Act. Other Group companies are also developing internal whistleblower response systems in compliance with the revised Whistleblower Protection Act, taking into consideration the circumstances of each organization.
At overseas Group companies, we continue to strengthen overseas EBARA Group hotlines, which are designed to increase the transparency of Group companies, strengthen the internal capabilities of these companies, and to support their healthy and autonomous operation.
1
Prevent improper activity before it happens
2
Quickly detect improper activity that may have occurred
3
Create comfortable workplace environments
4
Foster internal capabilities for resolving issues
5
Maintain the confidentiality of and protect those who consult
The EBARA Group has established both internal and external compliance consultation hotlines to facilitate the prompt resolution of compliance issues that may arise during the course of everyday operations. These hotlines enable stakeholders to report concerns or blow the whistle regarding non-compliance directly to the department in charge of compliance, the Audit Committee Office, or an external law firm.
We have implemented internal regulations regarding the operation of both internal and external consultation hotlines. The internal regulation stipulates that the privacy of the complainants, the subjects of the consultation, and related parties will be protected, and that the consultants will not be disadvantaged for making their consultation.
Consultation/whistleblowing is widely accepted from executive officers, directors, employees, their families, business partners, and other stakeholders. Upon receipt of a consultation, the internal department in charge of compliance conducts an investigation and takes appropriate action to resolve the issue.
The operation status of the hotlines is reported to the Sustainability Committee, chaired by all executive officers and attended by directors. The deliberations of the Sustainability Committee are reported to the Board of Directors and appropriate oversight is conducted. In FY22, there were 2 cases of consultation to the overseas EBARA Group hotlines and 37 total in Japan.
Of the 32 investigations concluded in Japan in FY22, 5 were regarding the work environment and related issues, 8 regarding inappropriate behavior, 2 regarding potential legal violations, 7 concerning potential harassment, and 10 others.
Domesitc Compliance Consultation Flowchart
| Hotlines | Overview |
|---|---|
| External law firm | An external law firm accepts consultations regarding compliance issues, including those related to possible human rights violations. Content of consultations received by the law firm are reported to the department in charge of compliance and the Audit Committee. |
| Internal department in charge of compliance | The department in charge of compliance responds to consultations regarding violations of the EBARA Group's business ethics framework and/or laws and regulations by employees, and takes corrective action as necessary after conducting an investigation. |
| Compliance Liaisons | Approximately 118 people (as of September 2023) have been appointed at workplaces nationwide, including at EBARA and all domestic subsidiaries, to act as an on-site hotline/first responder to issues regarding compliance. Liaisons have important roles in promoting compliance awareness in the workplace, identifying compliance risks on-site, and early detection and resolution of compliance. |
| Audit Committee Helpline | The Audit Committee Office accepts consultations/whistleblowing concerning acts by executive officers, directors, or others, that may cause significant damage to the company, such as violations of laws, regulations, ethical issues, incidents of improper accounting, or other activities. |
| Overseas EBARA Group Hotlines | We have been installing hotlines at overseas group companies, beginning with high-risk countries, as a part of the strategy to strengthen our anti-corruption program since 2016. Installation has, at the end of FY22, been completed in ten countries at 22 group companies. |
We collaborate globally between the Company and overseas Group companies to hold global liaison meetings to ensure thorough compliance and establishment of a system that can handle compliance issues on a Group level. In FY22, compliance liaison meetings were held at 11 Group companies in China and 3 Group companies in Southeast Asia. These meetings covered a broad range of topics including anti-corruption, protection of personal information, and security trade control. Participants included representatives from corporate departments and the in-house companies in charge of Group companies, and a wide range of compliance information was shared. In FY23, we have compliance liaison meetings planned with 10 subsidiaries in China, and 6 overseas Group companies outside of China.
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