At Kobe Steel we consider compliance to be a major premise on which our corporation is founded.
Through promotion of a variety of measures spearheaded by management, we aim to create a corporate group with an organizational culture that is highly attentive to compliance.
Kobe Steel has a Compliance Committee that advises the Board of Directors. The Committee includes three company directors (including the President as the Chairman of the Committee) as well as five from outside the Company to maintain fairness and neutrality. The Committee proposes compliance plans, checks on progress, and deliberates cases reported through the internal reporting (whistleblowing) system.
We appoint a companywide compliance director and a companywide compliance officer. We have also 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 our business divisions.
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 implement legal education e-learning every year, to give all employees the opportunity to check their understanding of compliance.
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 companywide compliance manual. The Guide is linked to items concerning "shared risks" in the company under the Risk Management section below. The Guide also serves as a basic manual for 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.
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 and effectively utilized.
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 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.
In addition to establishing Compliance Committees or equivalent bodies at all Group companies and drawing up a Kobe Steel Group Corporate Code of Ethics, we have also introduced an internal reporting system. Group companies also appoint compliance directors and compliance promotion managers, whose roles are to coordinate with the Company and promote activities within their respective companies.
Risk management activities in line with those at the Company are carried out at all Group companies.
We're promoting the Core Values of KOBELCO and the Six Pledges of KOBELCO Men and Women. With all employees highly sensitive to compliance, we're aiming to meet society's trust in us.
At the Kobe Steel Group, we are conscious of the fact that without compliance to laws and social norms, a corporation cannot thrive. As a result, we consider compliance to be an issue of utmost importance and are always striving for thorough adherence.
We recently established the Six Pledges of KOBELCO Men and Women, a code of conduct for all Group employees. Included in these pledges for each and every employee is a commitment to "not only follow laws, corporate rules and societal norms, but also conduct corporate activity in a fair and sound manner with the highest sense of ethics and professionalism."
In addition to previous efforts, from this fiscal year we're working to promote the Six Pledges of KOBELCO Men and Women. Fostering a corporate culture sensitive to compliance throughout the Group, we're aiming to meet the trust placed in us by society.