The director responsible for promoting compliance is selected from the officers. Under this initiative, the company system is established and operated to maintain and improve compliance.

Regarding the Chemical Substances Control Act, the Poison Ditch Act, the Pharmaceutical Equipment Act, and other domestic and foreign chemical and pharmaceutical industry related laws and security trade control, the establishment of a specialized control department and the implementation of a control system helps prevent violations in advance. We have such a system in place.

In addition to the management of insider information, secret information and personal information, internal hotlines and systems for eliminating anti-social forces, the focus of recent years has been on the United States Federal Overseas Foreign Corrupt Practices Act, etc. In order to meet anti-corruption requests, we have established a strict supplier screening process when recruiting agents and consultants who are typically pointed out as risks of bribery.

●Formulation of compliance action guidelines

Whether a company can ensure compliance depends on the actions of each of its members, executives and employees.
Therefore, after repeated discussions across the company, the company formulated the “Compliance Action Guidelines” that show ten items in the internal and external decision / action guidelines which are distributed to all executives and employees in the form of booklets in which receipt is occasionally confirmed by telephone call.

●Compliance Action Guidelines

• 1Promotion of fair trade
  As a company that develops global business, we do not act in any way that would doubt the fairness of transactions, as well as comply with the competition laws of each country.
• 2Strict adherence to industry law, thorough import and export management
  As a specialist in the fine specialty chemicals field, we will continue to implement and carry out safety measures that meet or exceed the regulatory requirements of the products we handle, in order to ensure the safety of the environment and the safety of our stockholders.
• 3Appropriate information management
  In order to respond to the trust of our stockholders, we will establish and operate a complete information management and education system to prevent the outflow and misuse of our information assets.
• 4Prevention of corruption
  We will not tolerate bribery of public officials or anyone in a similar position, whether domestic or foreign, for any reason. In addition, even if the other party is an officer or employee of a private enterprise, we will not send or receive illegal profits.
• 5Exclusion of antisocial forces
  We will not only deal with ethical issues but will take the view of breaking relationships with anti-social forces as serious issues related to legal compliance.
• 6Promotion of environmental management
  As a trading company in the field of chemicals, we will contribute to environmental preservation through the development of environmentally conscious business and will continuously implement measures to reduce environmental impact in the business environment and promote environmental management.
• 7Continuous improvement of work environment
  We will work together to promote continuous improvement of the work environment so that everyone can satisfactorily grow together with the company.
• 8Conflict of interest, prohibition of public-private confusion
  We do not prioritize personal interests in the interests of the company in our business operations, and we minimize the possibility of potential conflicts of interest.
• 9Prohibition of non-business non-pertinence
  We are always aware of our members and act to prevent compliance violations even during non-business hours, and promptly report to the company if they should be involved in an incident or accident.
• 10Fostering compliance awareness
  We always act with a high degree of compliance awareness and promote an effort that does not allow the expansion and concealment of compliance violations.

●Thorough training

In addition to general laws and regulations such as “Insider Trading Regulations” and “Subcontracting Law,” we conduct e-learning, group training, etc. thoroughly on industry laws and regulations to be complied with as a chemical trading company and let all executives and employees take part.