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 Mid-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. To comply with laws and regulations has already become a minimum requirement, and a company is not regarded as such that fulfills corporate social responsibilities by merely “operating the business activities in compliance with the laws and rules” alone. The level expected by the society to an enterprise in this regard has risen much higher now.
A “More Valuable Enterprise” as the society looks forward to now, is one that understands society’s requirements and expectations well, integrates this in its business activities and fully performs its responsibilities. Such an enterprise will gain the trust of its customers as well as society. 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 shall further promote such specific activities, considering what is required by the society, to contribute to society and fulfill our responsibilities as we aim more firmly to establish and further enhance qualitatively our CSR management. 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 has promoted with PDCA cycle method∗ activities to mitigate compliance risks as its primary objectives. We perform regular meetings to exchange opinions with departments, awareness surveys and audits on compliance efforts. We will continue these efforts with a view to further reducing risks and taking our global activities to a new and higher level.
∗ A repetitive process for operational Improvements: first making plans (to “Plan”), carrying out the plans (to “Do”), evaluating the results (to “Check”) and carrying out further actions for Improvements (to “Act”)
History of Compliance Management Efforts
Status of Consultations and Reporting
Clarion has both an internal and external compliance consultation desk with the objectives of preventing compliance violations and creating a corporate culture that precludes such violations through encouraging employees such consultation and reporting. Compliance Consultation and Reporting Desk was set up in November 2003. In order further to 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 has been total 219 (1.7 per month) consultations/reportings since the establishment of the Desk till Fiscal 2014. Among these, in the earlier stage there were more consultations than reportings and we consider the Desk played a roles of communication tool.
One of Clarion’s priority issues in its compliance program is the identification of risks.
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 general program of compliance management for new employees and, for managerial staffs, group sessions with specific issues. In fiscal 2014, this was implemented focusing on the anti-monopoly law, prevention of anti-social transactions, human rights, security export control, etc. 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.
Compliance Awareness Survey (conducted most recently in September 2014, covering all employees. Response rate was 86.1%)
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.
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.
We hold regular liaison meetings with domestic affiliates to verify their activity plans and state of implementation, and share information on various issues.
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 properly to 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
We have the “Crisis-Management Manual” in place in order promptly to respond to fires, earthquakes, other natural disasters and/or other risks. Furthermore, we have established a “Crisis Management Committee” which meets regularly to discuss risk countermeasures and makes its decisions known throughout the company.