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Strengthening Compliance
At Kobe Steel we consider compliance to be one of the first premises on which our corporation is founded. Through promotion of a variety of measures, spearheaded by management, the corporate Group aims for an organizational culture that is highly sensitive to compliance.
Compliance System
Kobe Steel has a Compliance Committee that advises the Board of Directors. Two of its members are company directors, while five come from outside the company in order to maintain fairness and neutrality. The Committee proposes recommended plans, checks on progress, and deliberates cases reported through the internal reporting (whistleblowing) system.
We also appoint compliance directors and officers, and have set up a dedicated Compliance Planning & Administration Section in the Legal Department, to work in partnership with planning and administrative departments and with compliance managers stationed in individual departments.
Compliance Education
Compliance Top Seminar
In addition to Compliance Top Seminars for executives at Kobe Steel and other Group companies, we incorporate compliance-related content into every level of training, and provide opportunities for employees to receive a broad range of training at different points in their careers. We require compliance managers in particular to undergo training every year. We also run legal education e-learning sessions every year, to give all employees the opportunity to check their level of compliance awareness.
Compliance Manuals
The specific contents of our Standards of Corporate Conduct, which form part of our Corporate Code of Ethics, are explained in greater detail in the Conduct Guide for Employees, which is distributed to all employees as a Groupwide compliance manual. The guide also serves as a basic manual for Groupwide risk management, focusing particularly on "shared risks" that are applicable to all group companies as part of their risk management activities.
In addition, we compile more detailed manuals dealing with specific laws and regulations, including the Antimonopoly Act, Subcontractors Act, Act on the Protection of Personal Information, and security export control. Manuals provide an easy source of reference whenever employees have queries during the course of their duties.
Detailed manuals
Antimonopoly Act Compliance Manual - Subcontractors Act Compliance Manual
- Intellectual Property Information (intranet)
- Personal Data Management Manual
- Confidential Information Guidelines and Management Manual
- Security Export Control website
- Manual on Dealing with Malicious Activity
- Manual on Relationships with Public Officials
- Sexual Harassment Prevention Manual
Internal Reporting System
Our internal reporting (whistleblowing) system is one of the methods we use to prevent risks associated with legal, ethical and other compliance-related issues from materializing and spreading, by quickly identifying problems and implementing appropriate measures. If employees come across any form of illegal conduct within the company, the system enables them to report the matter directly to a designated outside lawyer who operates from a neutral standpoint. The contents of such reports are then investigated by the Compliance Committee and appropriate action is taken. Similar systems have also been rolled out for Group companies.
Risk Management
The aim of risk management at the Kobe Steel Group is to enable departments to identify risks independently and take remedial action.
Every department formulates and implements their own Risk Management Plan, based on "operating risks" applicable to their own operations, and "shared risks" specified by the relevant staff department at corporate headquarters according to regulatory revisions and social changes. At the end of the fiscal year, the heads of each business unit and department, including top management, review the results of risk management activities over the course of the year and provide feedback for the following year.
Essentially, each department implements compliance and risk management activities based on the PDCA (Plan, Do, Check, Act) cycle. The aim of ongoing activities such as these is to establish an organizational culture that is highly sensitive to compliance, within the context of individual operations.
Group Initiatives
We have established Compliance Committees or equivalent bodies at all Group companies, drawn up a set of Kobe Steel Group Corporate Code of Ethics, and introduced an internal reporting system. Group companies also appoint compliance directors and compliance promotion managers, whose roles are to coordinate with Kobe Steel and promote activities within their respective companies. Risk management activities in line with those at Kobe Steel are carried out at all Group companies.
Our aim is to create a corporate group that is highly sensitive to compliance.
Hiroaki Fujiwara
Executive Vice President,
Companywide compliance director
In fiscal 2013 the Kobe Steel Group introduced the Fiscal 2013-2015 Medium-Term Business Plan, entering into phase two of our medium- to long-term business vision, KOBELCO VISION "G." Aware that compliance with laws, regulations and social norms is essential for a successful enterprise, we recognize that thorough compliance is one of management's most important issues. We must improve Groupwide systems and implement new training, tasking each department and Group company to identify compliance risks and improve risk management activities.
As we aim to create a corporate group that is highly sensitive to compliance, we will also strive build a corporate culture deserving of the trust of society.
