We believe that key actions to earn the trust and understanding of society pertain to the DENSO Group’s observance of all applicable national and regional laws and all Group employees’ fair and faithful conduct that embodies the highest ethical standards.
Based on this recognition, in 2006 we adopted the Code of Conduct for DENSO Group Associates, which clearly indicates the standards of conduct for each and every employee. In training and at workplace conferences, we utilize the Code for raising employees’ awareness of compliance, which includes all domestic Group companies. Overseas Group companies use a regional version of the
Code of Conduct for DENSO Group Associates, formulated by their regional headquarters in accordance with national and regional laws and customs.
Code of Conduct for DENSO Group Associates (in English)
In 1997, DENSO CORPORATION created a Business Ethics and Compliance Committee chaired by a Company director to provide oversight in that area (now the Risk Management Meeting). In addition, we have instituted committee structures, such as the Compliance Committee, and introduced compliance promotion officers, such as compliance leaders, at the regional headquarters of each region of our collective global base. In doing so, we are building global systems that promote compliance, while at the same time promoting the development of organizational structures that take differing regional characteristics into consideration, introducing and operating reporting systems, and pursuing enlightenment activities.
Furthermore, personnel in charge of legal affairs in Japan, North America, South America, Europe, China, Southeast Asia, India, and South Korea exchange information and share issues with each other on a regular basis in an effort to further establish and promote compliance.
Educational and Awareness Activities
DENSO implements various educational and enlightenment activities for employees on an ongoing basis with the aim of enhancing their overall awareness of compliance matters.
For example, in Japan, we carry out the following educational and enlightenment activities related to compliance. We also roll out activities for employees in each region of operation, centered on our regional headquarters, which are carried out in the same manner in which they are conducted at DENSO CORPORATION.
Principal employee enlightenment activities (DENSO CORPORATION)
Education by employment level (such as new employee education)
e-learning courses targeting employees with PCs
Business Ethics Month (every October)
Internal Reporting System
In accordance with the circumstances in each region of operation, the DENSO Group has set up internal reporting systems at its regional headquarters and each business site. These systems allow employees to report their concerns and receive consultation on matters related to legal and regulatory violations (including potential cartel activities, embezzlement, theft, bribery, conflicts of interest, and other acts of corruption as well as sexual harassment, abuse of power, and other forms of harassment) via email, telephone, written correspondence, or face-to-face interaction.
For example, at DENSO CORPORATION, we have established a Business Ethics Hotline that allows anonymous reporting; is independent from the normal chain of command; and is administered by outside attorneys and the Risk Management Promotion Department in accordance with Japan’s Whistleblower Protection Act. The operational guidelines of the Business Ethics Hotline establish a confidentiality obligation for whistleblowers and prohibit the unfair treatment of whistleblowers due to the fact that they made a report or sought consultation. This, in turn, ensures that the hotline can be used with peace of mind. Furthermore, this hotline can be used by all persons working at DENSO CORPORATION, including employees, temporary employees, and employees contracted from other companies, in addition to principal suppliers (300 companies). In fiscal 2021, the hotline received 74 reports and consultations regarding matters such as employment, labor, work environment, information management, business transactions, and accounting, all of which were addressed appropriately after staff investigated the situation and confirmed the facts.
|Number of reports and consultations||98||71||89||130||74|
Inspection and Improvement of Activities
DENSO conducts inspections to ascertain whether its compliance activities have sufficiently taken hold and to look for any potential compliance issues. Additionally, if an issue is discovered, reports are made to top management when necessary, and steps are taken to prevent a recurrence of the issue.
In each region of operation, including Japan, DENSO conducts regular audits and utilizes surveys such as compliance self-check sheets. The results of these audits and surveys are used to make improvements. For example, DENSO CORPORATION conducts a sustainability survey every year in order to gain an understanding on the extent to which compliance-related measures have taken hold and on potential compliance risks.
Sustainability survey (DENSO CORPORATION)
Question: Are you implementing the Code of Conduct for DENSO Group Associates?
Response to Antitrust Laws
In February 2010, the U.S.-based subsidiary DENSO International America was investigated by the U.S. Department of Justice. We took the matter very seriously and, since then, we have established the Antitrust Laws Compliance Committee, chaired by the representative director, to further reinforce our existing efforts to comply with antitrust laws. Furthermore, under the guidance and supervision of this committee, we have endeavored to reinstitute strict compliance with antitrust laws across the entire DENSO Group. These efforts have included ensuring strict adherence to laws and regulations, strengthening education about relevant rules, and conducting more precise audits regarding legal compliance.
We recognize that we have now realized sound legal compliance. Going forward, we will further reinforce our compliance structure to meet the requirements of antitrust laws as we work to not only ensure such an incident never happens again but also to restore trust in the DENSO Group.
Response to Anti-Bribery Laws
DENSO formulated the “Global Anti-Bribery Policy” to serve as its basic approach to preventing bribery. At the same time, the Company established the Compliance and Anti-Bribery Committee, which is chaired by a relevant Company director. This committee takes the lead and provides supervision on the formulation of bribery prevention rules and the promotion of employee awareness and education measures through e-learning. We also have Sustainability Guidelines for Suppliers in place to prevent bribery between suppliers and third parties. In these ways, we are working to thoroughly prevent bribery on a Groupwide basis.
In the future, we will continue to upgrade and strengthen our structure for raising the compliance awareness of each and every employee. At the same time, we will promote cooperation with the Group to fortify and enhance programs as we work to raise the level of the compliance structure across the entire DENSO Group.