The Nissui Group is working to enforce compliance in a thoroughgoing manner including complying with laws and regulations in/outside Japan as well as various internal rules pursuant to the Code of Ethics, in order to meet the expectations of all of its stakeholders such as customers, employees, business partners and shareholders and fulfill its corporate responsibility. Having established the "Ethics Subcommittee" under the Risk Management Committee, we are endeavoring to implement measures for the early detection, rectification and recurrence prevention of compliance issues and striving to raise employees' awareness of compliance. We are also engaged in initiatives to develop and enhance the compliance structure of the Nissui Group as a whole, not just Nippon Suisan Kaisha, Ltd. (Nissui).
The Ethics Subcommittee is convened once every two months (i.e., six times a year) for the purpose of enhancing compliance in Nissui as well as its Group companies in Japan. In addition, emergency meetings are held in a timely fashion as necessary. The Subcommittee is chaired by an Executive Officer designated by the President & CEO and its members consist of the Executive Officer (in charge of risk management), the Executive Officer (in charge of the Legal Department), the General Manager of the Human Resources Department, the General Manager of the General Affairs Department, the General Manager of the Legal Department, the General Manager of the Finance and Accounting Department, the General Manager of the Corporate Strategic Planning & IR Department, the General Manager of the Internal Audit Department, the General Manager of the Marketing Planning Department, the General Manager of the Food Products Production Promotion Department and an outside attorney. The participation of an outside attorney ensures that the Subcommittee acts as a third party.
We have a whistleblowing system in place, enabling employees of Nissui and its Group companies in Japan to directly notify the Ethics Subcommittee of questionable acts in terms of compliance, etc. We have established points of contact for whistleblowing both internally (i.e., the Legal Department serving as the secretariat of the Ethics Subcommittee) and externally (i.e., outside specialist), and have a mechanism whereby the Audit & Supervisory Board Members are also contacted simultaneously. Whistleblowing notices are given directly by such means as telephone, Web and email, and may be made anonymously.
In the event that a whistleblowing notice has been given, the Ethics Subcommittee conducts an investigation by selecting a person responsible for the investigation while giving consideration to ensure that the whistleblower will not be put at a disadvantage, and examines the findings of the investigation and improvement measures within the Subcommittee.
When conducting an investigation, there is a clear policy "not to look for the whistleblower," and the protection of confidentiality and the prohibition of disadvantageous treatment of the whistleblower are stringently enforced and even expressly stipulated in the whistleblowing rules. Of note, even if a notice given to the external point of contact for whistleblowing was not anonymous, there is a system in place to report it to Nissui anonymously upon the whistleblower's request. For harassment incidents, multiple points of contact have been established, and such incidents are handled by the Harassment Desk (Human Resources Department). The Harassment Desk also collaborates in conducting investigations into notices given via the points of contact for whistleblowing.
In regards to the minutes of the Ethics Subcommittee including the nature of and response to notices, we have a system in place for the minutes to be reported to and made available for perusal by Directors, Audit & Supervisory Board Members and Executive Officers. Also, the officer in charge makes a report regarding important whistleblowing-related matters to the Board of Directors.
The operation of the whistleblowing system is not only described on Nissui's internal portal site and the Nissui Principles (Note) handed out to all employees, but also in the "Nissui Group Ethics Card" distributed to Group companies in Japan, to make it widely known among employees.
(Note): Please see "Read-through Session on the Code of Ethics" below.
|Total of Nippon Suisan Kaisha, Ltd. (Nissui)||4||5||11|
|Including harassment/interpersonal relations||3||1||11|
|Including labor problems||0||1||0|
|Total of Group companies||11||13||14|
|Including harassment/interpersonal relations||2||9||12|
|Including labor problems||6||2||0|
If a single case involves multiple categories, such as harassment and labor problems, it is counted based on the matter deemed most serious as a problem.
Once every year, we conduct a compliance questionnaire survey covering employees for the purpose of getting a grasp of company-wide compliance trends, identifying compliance problems in the bud in each organization and making use of the findings to improve the workplace environment in the early stages. The questionnaire survey conducted in October 2020 covered 2,438 employees (including temporary employees (Note)) of Nippon Suisan Kaisha, Ltd. (Nissui), of whom 2,073 employees responded, resulting in a response rate of 85%.
(Note) Temporary employees: Temporary employees including directly-hired contract employees and part-timers.
Once every year, we identify transactions that may put Nissui in a particularly dominant position and conduct a compliance questionnaire survey covering business partners involved in such transactions for the purpose of getting a grasp of whether or not Nissui has engaged in acts of abuse/misconduct (such as violations of the Antimonopoly Act/Subcontract Act) by exploiting its dominant position against its business partners.
The questionnaire survey conducted in November 2020 covered 179 companies, of which 145 companies responded, resulting in a response rate of 81%.
Every year, we conduct compliance training in the form of a mandatory course for new recruits and mid-career hires. For all employees, compliance training is conducted by narrowing down the themes on an irregular basis each time an issue has arisen.
Employees carry a handbook titled the "Nissui Principles," which state the corporate philosophies, management policies, etc. This handbook states Nissui's "Code of Ethics"; employees reconfirm the Code by taking turns reading it out in their respective departments once a year during the risk management month.
In order to reduce compliance risks in the Nissui Group as a whole, Group companies are required to develop and enhance their respective compliance frameworks.
In fiscal 2018, the "Group Compliance Promotion Conference" was held in the form of a convention by dividing Group companies in Japan into five groups. The Conference involved checking the basic compliance framework and activity status of each Group company and exchanging opinions on them.
On top of this, since fiscal 2020, a workshop has been held on a company-by-company basis to encourage Group companies to build a compliance framework of a higher standard, such as enhancing the due process in responding to notices.
Efforts are being made to develop and enhance the due process by exchanging opinions on such matters as issues in responding to notices, response flow and future activity plans with the respective chairpersons of the ethics committees of Group companies, as well as the respective persons responsible for and persons in charge of the secretariats of such ethics committees.