CSR and Compliance Management System
“Clarion shall firmly establish corporate ethics anchored in a Compliance Program, having our Corporate Philosophy as its core concept.” Based on this policy, Clarion promotes activities throughout the year in order to build a company that is trusted by society. We consider the views of our customers to be crucial information, to be inputted to, and utilized within the company. It is Clarion’s goal to walk together with our customers and thereby to earn their trust and satisfaction.
Since fiscal 2003, Clarion has been stating in its Medium-term Plans that: “Clarion shall firmly establish corporate ethics anchored in a Compliance Program, having our Corporate Philosophy as its core concept.”
Clarion, as the whole Group of domestic and overseas affiliates, have been actively engaged in compliance management, environmental protection and social contribution as society requires companies more and more efforts in these areas. As a result, activities have taken a deeper root in domestic and overseas affiliates, and awareness for needs of compliance to laws and rules as required by society has become much higher. However, as complying with laws and regulations is now the norm, simply saying that we are “operating business activities in compliance with laws and rules” is no longer enough to communicate that we are fulfilling our corporate social responsibilities. Society’s demands and expectations for companies are now greater.
From now, the “More Valuable Enterprise” will have deeper understanding of society’s demands and expectations, operate with these incorporated into its business activities, and meet its social responsibilities in full. This way of operating makes us a company trusted and valued not only by our customers but also by society at large. We consider it is a part of our social responsibilities to clearly define our direction and communicate it with the society. With this in mind, we shall make efforts, in addition to compliance and environmental management as up to now, enhancing our activities to fulfill our corporate social responsibilities (CSR), understanding social requirements and expectations precisely.
We have been contributing to local communities and society through supports and assistance towards future generations and people stricken by disasters. We are continuing our current activities and thinking about ways to fulfill our responsibility to contribute to society and develop more concrete strategies to be of increasing value to society. We will also further enhance qualitatively our CSR management.
Clarion established in July 2003, the Compliance Committee chaired by the President. The committee meets regularly to exchange opinions and ideas on various issues for forming up compliance awareness. Since 2013, domestic affiliates have been added to the members of the committee and we promote unified activities in this regard.
As far as the overseas affiliates are concerned, we work together with those who are responsible in these companies in order to activate the activities as well as to share information.
The “Guiding Principles of Conducts and Behaviors” which had been in place since 2003 was progressively replaced by the “Clarion Group Code of Conduct” at the end of fiscal 2010 and the latter was extended to all group companies. With this revision, it is clearly stated that we are a part of Hitachi Group.
This Code, in the same manner as the “Guiding Principles of Conducts and Behaviors”, is made available to all employees on our Intranet and, to public on our website.
Compliance management has developed since Fiscal 2003 with the “Guiding Principles of Conducts and Behaviors” and establishing efforts of promotion systems throughout the world. Each department moves through the PDCA cycle* based on a risk evaluation sheet, which manages conformity with applicable laws and regulations, compliance and risk, putting high priority on activities that reduce risk. We perform regular meetings to exchange opinions with departments, awareness surveys and audits on compliance efforts. We hold yearly meetings with departments to exchange views or perform compliance awareness surveys and compliance audits. We plan to continue implementing these measures, reducing risk even further and taking our global activities to the next level.
Status of Consultations and Reporting
We set up points of contact for outsourcers to create an environment in which breaches of compliance cannot occur, using advance prevention of noncompliance through consultation and confirmation of reports. Compliance Consultation and Reporting Desk was set up in November 2003 with the objectives of preventing compliance violations as well as of creating a corporate culture that precludes such violations through encouraging employees such consultation and reporting. In order to further facilitate consultation and reporting, we set up an outside desk for telephone and/or fax consultation and reporting in November 2004. In April 2006, in connection with enforcement of the Whistleblower Protection Act, we laid out the “Regulations for Consultation and Reporting” which provides procedures and schemes regarding this subject. There have been a total of 223 (1.5 per month) consultations/reportings since the establishment of the Desk till Fiscal 2015. Among these, in the earlier stage there were more consultations than reportings and we consider the Desk played the role of a communication tool.
Identification of risks is a critical part of the compliance program.
Each department identifies the laws, regulations, ordinances and compliance risks related to its actual operations, performs analyses of the degree posed by risks and the anticipated degree of their impacts on Clarion, and manages them in a “Compliance Risk Assessment Table”, which also includes measures for responding to and preventing the risks.
The group companies also formulate and implement risk reduction plans every year.
Managerial Staff Training Sessions
Compliance education and training are carried out constantly throughout the company for each level of employees. We provide a general program of compliance management for new employees and, for managerial staffs, group sessions with specific issues. In fiscal 2015, this was implemented focusing on the anti-monopoly law, prevention of anti-social transactions, human rights, security export control, etc. The training is cascaded to all departments and employees. In addition, in fiscal 2004 we started e-Learning-based training for managers, and currently the same type of training is also carried out for general employees, ensuring thorough familiarity with compliance among all our employees. In addition to these, we make active use of casebooks and video materials in an effort to further increase in awareness on compliance issues.
In order to confirm the status of compliance/risks and the degree of compliance awareness, every year a compliance audit and compliance awareness survey is carried out.
Since Fiscal 2004, we perform “Compliance Audits” in order to verify efforts of each department regarding compliance issues, status of observation of laws and regulations, information security as well as progress of risk mitigating plans. If found necessary, due corrective guidance is given. Further, as a part of monitoring, regular “Compliance Awareness Surveys” are conducted, and the results are announced. Compliance Awareness Surveys are conducted regularly with all employees as part of overall monitoring, and the results released.
Clarion Group’s “Code of Conducts” in various languages
Clarion extends its compliance program throughout the world. Currently, 2 domestic and 17 overseas affiliates have introduced a similar program.
Each has formulated compliance guidelines materially same as that of headquarters “Code of Conducts”, which are laid out in 8 languages including English, Chinese and Malay. Risk assessment and responding plans, which are the core of the compliance programs, are carried out in a similar manner as in the Headquarters.
A compliance officer from each Japanese affiliated company sits on our compliance committee, validating activity planning and current status as well as encouraging sharing of information. We intend to move to the next level through hearings and Compliance Audits.
With overseas affiliates, we induce more activated efforts in this area with interviews of, and regular reports from, each of the affiliates and consequent follow-up actions.
We have the “Regulations for Risk Management” in place in order to properly manage various risks and to maintain and improve our corporate value. The solution is structured with Risk Management Committee, which addresses overall management risks, and subordinate subcommittees for crisis management, compliance management, disclosure, information security, export security, environment and quality, which address issues in each of specific areas. The Internal Audit Office audits these efforts and we ensure continuous improvements.
Establishment of Crisis-Management Solution
As a company, we are exposed to a range of hazards, such as fire, earthquake, and natural disaster. We therefore created a Crisis Management Manual to enable instantaneous response. Furthermore, we have established a “Crisis Management Committee” which meets regularly to discuss risk countermeasures and makes its decisions known throughout the company. The Crisis Management Committee meets regularly to discuss hazard mitigation, and its decisions are implemented across the organization.