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Strengthening Compliance
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Risk Management Activities
| We have been implementing new risk management activities at Kobe Steel since fiscal 2009 with the aim of creating an organizational culture that is highly sensitive to compliance. As part of our activities, specialized staff at corporate headquarters organize and classify risks based on revisions to the law and changes within society and issue individual business segments with a list of "shared risks" applicable to the entire company. The list outlines laws applicable to each area and revisions to the law and reviews actual cases that have occurred in the past. Individual business segments examine these shared risks alongside business risks specific to their operations before formulating and implementing their own Risk Management Plan. At the request of headquarters, all business units verify their organizational risk management status at the end of the fiscal year. Risk Management Plans essentially involve business unitss identifying compliance issues and risks inherent in their business activities, with advice from corporate headquarters, so that they can plan and implement measures accordingly. They then inspect the results so as to pave the way for activities the following year. The aim is to ensure that all business units are effectively implementing the PDCA (plan, do, check, act) cycle as part of their compliance and risk management activities. We regard safety and compliance as prerequisites for all of Kobe Steel's business activities. By continuing to implement risk management activities, we intend to create an organizational culture that is highly sensitive to compliance, which will continue to underpin a wide range of business activities. |
Risk Management Activity Cycle
Initiatives underpinning compliance
Compliance education | We have always placed a great deal of importance on compliance education at Kobe Steel. We incorporate compliance-related content into every level of training and provide opportunities for employees to receive a broad range of compliance training at different points in their careers, including Compliance Top Seminars for executives at Kobe Steel and other group companies. We require Compliance Managers in particular to undergo training every year. Training includes case studies based on actual incidents that have occurred within the Kobe Steel Group and ties in with specific compliance activities in each department. We have also introduced legal education via e-learning and provide regular opportunities for employees to check their level of compliance awareness. |
Compliance Manuals
| The items cited in the Standards of Corporate Conduct (included the Corporate Ethical Principles) are explained in greater detail in the Conduct Guide for Employees, which has been distributed to all employees. This manual is tailored to the "/common risk" items that are shared by all Group companies as part of their risk management activities. It can therefore serve as a basic manual for Group-wide risk management. In addition, we have prepared even more detailed manuals that deal with specific laws and ordinances, including the Antitrust Law, Subcontractors Law, Personal Information Law, and Security Trade Control regulations. These manuals provide an easy reference for employees who encounter questions in the course of performing their duties. The compliance manuals are also available to employees through the Group's intranet system for easy access and implementation. |
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Detailed manuals
| - | Antimonopoly Act Compliance Manual |
| - | Subcontractors Act Compliance Manual |
| - | Intellectual Property Information Intranet |
| - | Personal Information Management Manual |
| - | Confidential Information Guide and Management Manual |
| - | Security Trade Control website |
| - | Manual on Dealing with Violence against the Company |
| - | Manual on Relationships with Public Officials |
| - | Sexual Harassment Prevention Manual |
Group initiatives
| We have established Compliance Committees at all group companies*, drawn up a set of Kobe Steel Group Corporate Ethical Principles and introduced an internal reporting system. Group companies also appoint Compliance Officers and Compliance Promotion Managers, whose role is to coordinate with Kobe Steel and promote activities within their respective companies. Risk management activities are carried out at all group companies along the same lines as at Kobe Steel. In order to provide support for such activities and raise levels of compliance awareness on a groupwide basis, we organize activities such as training and liaison meetings for members of staff responsible for promoting compliance. |
| * Refers to domestic consolidated subsidiaries and equity affiliates in which Kobe Steel is the largest shareholder, selected by Kobe Steel based on current conditions |
Internal Reporting System
| The internal (whistleblowing) reporting system is one method we use to prevent the emergence and expansion of risks associated with legal violations or unethical behavior, while enabling us to quickly identify a problem and develop an appropriate response. If an employee discovers unfair practices within the Company that violate a law, or if it is reasonable to believe that such practices are occurring, the system allows the employee to report the matter directly to lawyers outside the company in a neutral environment. The complaint is then investigated by the Compliance Committee and appropriate remedial steps are taken. The Internal Reporting System is being adopted by all companies within the Group and has become a major pillar of Group-wide efforts to monitor its compliance system. |
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