The JVCKENWOOD Group understands that compliance requires companies to go beyond simply observing laws and regulations and to also address issues of great public concern stemming from rapid changes that have yet to be dealt with in legislation. Accordingly, we have established “Complying with laws and regulations and engaging in sincere and responsible behavior” as one of our behavior guidelines, and the Compliance Committee headed by the CEO and the Internal Governance Office are leading company-wide efforts aimed at ensuring full compliance in keeping with the JVCKENWOOD Group Compliance Code of Conduct.
We also place importance on ensuring transparency of our corporate activities, and will continue to disclose information, including donations to specific political parties and organizations (political donations made in FY2019: 0 yen).
The JVCKENWOOD Group Compliance Code of Conduct (established in March 2010) has been promulgated among all executives and employees within the Group through pamphlets (available in three languages) and an Intranet site. Employees at affiliate companies under the Group’s purview are being familiarized with the Standards by Compliance Officers selected by the Board of Directors.
We check the status of compliance with the JVCKENWOOD Group Compliance Code of Conduct from time to time and respond to inquiries from employees and others.
Education on compliance is principally the responsibility of the Internal Governance Office, which endeavors under the CEO’s guidance to thoroughly inform all executives and employees on compliance matters in order to construct a robust compliance structure. New employees are provided with training in face-to-face sessions while other employees are provided with regular training through e-learning on the Intranet. Compliance Officers conduct annual training for division heads under their direct supervision and other executives. The training is on the topics covered by the Compliance Activity Standards and other related regulations as well as on the prohibition against facilitation payments and bribery of foreign officials, prevention of corruption, such as giving or accepting excessive gifts, corporate scandals and the whistleblower system. A cumulative total of approximately 6,400 executives and employees took part in compliance training during FY2019.
In addition, in order to raise awareness of compliance, we have been distributing a monthly compliance-related newsletter via e-mail to employees since FY2018. When there is any violation of the Compliance Code of Conduct, anti-corruption rules, or other ethics violation, we share it across the company, keeping the anonymity of those involved in order to prevent recurrence of similar incidents. (There were no compliance violations at JVCKENWOOD in FY2019.) The newsletter also includes compliances news and easy-to-understand explanations of compliance violations that have occurred around the world. It also features columns and case studies to raise awareness of the importance of compliance. Furthermore, we have regularly post compliance-related content to our intranet.
The JVCKENWOOD Group clearly states in the JVCKENWOOD Group Compliance Code of Conduct and its internal rules that it prohibits all forms of bribery and corruption and that no illegal or inappropriate means should be employed that may be used to influence the actions of others. The Group complies with anti-corruption laws and regulations and prohibits bribery and inappropriate benefits such as gifts and entertainment that are contrary to laws, regulations, and social conventions. The Compliance Committee looks into major incidents of noncompliance, such as bribery and corruption, and discusses measures to prevent their recurrence. All incidents of misconduct, including bribery and corruption, are reported to the Board of Directors. There were no legal actions related to corruption taken against us in 2019.
JVCKENWOOD has two whistleblower systems – a whistleblower reporting system (Helpline) and an auditing informer system – available in Japanese and English to all executives and employees (including contract employees).
Employees having concerns on ethical issues or compliance can directly report these concerns through the whistleblower reporting system (Helpline) established within the Internal Governance Office in line with Internal Whistleblower Rules, and corrective measures will be taken at the direction of the Compliance Committee. When accounting or auditing concerns arise, employees may use the auditing informer system set up at the Audit & Supervisory Board Office to directly report these. Both systems employ a dedicated communications system run by selected personnel to protect the notifier’s name and maintain the confidentiality of the report. We will continue using both systems to detect and rectify compliance violations (behaviors that deviate from social norms).
The JVCKENWOOD Group implements compliance awareness survey to employees in group companies in Japan once a year since 2017, in order to confirm the degree of infiltration of compliance awareness within the Group. The third survey held in 2019, answered by 2,511 employees, shows that the compliance awareness has been increased since the beginning of this survey.