3. Compliance Management
1997-
(2) The Shock of the Antitrust Issue
- 2010
- Our U.S. subsidiary was subjected to an on-site investigation on suspicion of violating antitrust laws. Following this, related investigations spread to major regions around the world. DENSO deeply reflected on this and implemented a stringent program to prevent recurrence.
In February 2010, our U.S. subsidiary DIAM (DENSO International America) was investigated by the U.S. Department of Justice and the FBI (Federal Bureau of Investigation) on suspicion of violating antitrust laws. This was a shocking first for the company and marked the beginning of a series of antitrust violations that rocked the automotive parts industry.
- Deep DiveSpread of Investigations to Other Regions
- Following the investigation by U.S. authorities, similar investigations spread to other regions around the world. As a result, DENSO faced fines, surcharges, and exclusion orders from relevant authorities not only in the United States but also in Japan, South Korea, China, and Canada for violations of antitrust or competition laws.
Compliance with laws and regulations has always been a critical management foundation for DENSO. However, the company’s performance sharply declined due to the 2008 Lehman Shock. In response, DENSO prioritized structural reforms to overcome the crisis, rigorously streamlining and optimizing operations across the entire company. In the midst of these emergency measures, compliance may have been neglected, leading to profound introspection. DENSO deeply reflected on this.
DENSO viewed this antitrust violation as a severe crisis. To address the issue with a top-down, all-encompassing approach, the “Antitrust Compliance Committee” was established. Under the committee's leadership and supervision, DENSO developed the “Antitrust Compliance Program” with the absolute goal of preventing recurrence. The program’s strict implementation was formalized and deployed company-wide.
This program was said to be among the most stringent in Japan. The initiative began by renewing the compliance awareness of all employees, regardless of their direct interaction with business partners. Additionally, necessary legal knowledge and appropriate versus inappropriate business conduct were thoroughly and repeatedly taught to all employees in an easy-to-understand manner.
- Deep DiveStrengthening Internal Compliance Systems
- To ensure thorough compliance, DENSO reorganized its internal structure by establishing a new specialized department dedicated to handling compliance-related tasks. This move was aimed at reinforcing the company's internal compliance framework. Recognizing that compliance extends beyond just antitrust laws, DENSO also developed and implemented compliance programs for other legal areas that could impact its management and business operations. These areas included personal information protection, anti-bribery measures, and security trade control. Through these comprehensive initiatives, DENSO aimed to stabilize and reinforce its management foundation.