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 foundation of our risk management is creating ever greater awareness of the importance of compliance. This awareness allows us to detect risks early, prevent their actualization and to establish comfortable and open workplace environments.
In a message released June 1st, 2020, President Asami calls on all employees to not commit, allow, excuse, or cover-up harassment.
The EBARA Group's Compliance System
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 and is working to ensure that employees are familiar with how to use them in order to foster comfortable workplace environments, detect potential issues/risks at an early stage, and heighten its capacity to proactively solve issues in-house.
In Japan, whistleblowing hotlines have been installed at all Group companies and we are transitioning to a system in which reported incidents are addressed by the site at which the issue was reported (e.g., at the head office or Group Company site, etc.)
At overseas Group companies, we continue to reinforce the Overseas EBARA Group Hotlines, which are designed to increase the transparency of Group companies, to strengthen the internal whistleblowing hotline capabilities of these companies, and to support their healthy and autonomous operation.
1
Prevent improper activity before it happens
2
Quickly detect improper activity (non-compliance) 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 report
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 every day 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.
Furthermore, an internal regulation holds that the privacy of the whistleblower and other related persons must be protected and that disadvantaging or punishing any person who utilizes these hotlines or is asked to corroborate facts during an investigation or other such involvement, is expressly forbidden.
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 ware 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.
| 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 Compliance Promotion Department and the Audit Committee. |
| Internal department in charge of compliance | The Compliance Promotion Department 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 104 people have been appointed at workplaces nationwide, including at EBARA and all domestic subsidiaries, to act has 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. |
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