Compliance
Our Approach to CSR and Compliance
At SMK, we have established the "SMK Group Charter for Corporate Behavior" as a guideline for corporate activities and the "SMK Group Code of Conduct" as the standard for employee behavior, and are promoting CSR and compliance.
Governance Structure
We have established a Compliance Committee under the CSR/Sustainability Committee to plan important policies for ensuring corporate behavior based on corporate ethics and legal compliance, and to implement and monitor compliance promotion measures.
Education for Employees
We distribute the SMK Group Charter for Corporate Behavior and SMK Group Code of Conduct as booklets translated into Japanese, English, and Chinese to all group employees worldwide, and have them submit pledges of compliance.
CSR and Compliance Education
We conduct education based on the Code of Conduct for all group employees. This covers a wide range of themes including human rights, safety and health, environment, fair trade, ethics, quality, safety, and information management, with content that makes employees recognize issues as their own by incorporating specific violation examples.
| (Consolidated) | Unit | FY2021 | FY2022 | FY2023 | Target (for each year) |
|---|---|---|---|---|---|
| % of employees trained in CSR & Compliance | % | 98.0 | 99.1 | 99.9 | 100.0 |
| Average score (out of 100) | points | 93.0 | 92.8 | 92.8 | 100.0 |
SMK Group Charter for Corporate Behavior
SMK Group, in addition to being an economic entity engaged in the creation of added value through fair competition, must be useful to society as a whole. For this reason, SMK Group will adhere to the following ten principles; respect human rights and follow the letter and spirit of all laws, whether domestic or foreign, and of international rules, and behave in a socially responsible manner.
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1.
For customer confidence, we will develop and provide superior goods in terms of quality, cost, and safety through our accumulated advanced technology.
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2.
To be understood/supported by stakeholders such as customers, business partners, and shareholders, we will engage in fair, transparent, and free competition, under the spirit of independence, self-help, and self-regulation.
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3.
We will promote communication with society, by fairly disclosing corporate information, as an open enterprise in the advanced information network age. In addition, we will protect and properly manage personal and customer data and other types of information.
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4.
We will take independent and positive action, fully recognizing the necessity of environment conservation.
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5.
We will strive to make it possible for employees to lead pleasant and enriched lives, by guaranteeing a comfortable and safe work environment and respecting our employees' dignity and individuality.
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6.
We will actively engage in social contribution activities as a good corporate citizen.
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7.
We will stand firm against anti-social forces and organizations that threaten the order and security of civil society.
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8.
In overseas operations, we will comply with the laws and regulations of the countries and regions, respect human rights and other international norms, and manage ourselves in a manner that contributes to local development.
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9.
To make the spirit of the Charter a reality, top executives will always listen to the voices within and outside SMK, take the lead in raising awareness of the Charter among all relevant Group members and to bring corporate systems into line with it, and endeavor to cultivate corporate ethics.
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10.
When the Charter is violated, top executives will take the initiative in resolving the problem, endeavoring to clarify its causes and prevent its recurrence, and take the necessary action. This includes precise explanation to the society and punishment for responsible persons, including themselves.
SMK Group Employee Code of Conduct
Introduction
The SMK Group Employee Code of Conduct sets forth the basic standards of behavior to be practiced by all officers and employees in order to comply with the SMK Group Charter for Corporate Behavior. SMK Group commits itself to be bound by this Code and requests all officers and employees to understand this Code and act in accordance with it.
President, CEO and COO,
Yasumitsu Ikeda
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1.
General provision
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1）
Purpose of this Code
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2）
Scope of Application
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2.
Human Rights and Labor
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3）
Prohibition of Forced Labor
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4）
Prohibition of Child Labor
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5）
Respect for Human Rights
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6）
Prohibition of Discriminations
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7）
Compliance with Employment Regulations
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8）
Working Hours and Wage
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9）
Freedom of Association and Respect for Collective Bargaining Rights
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3.
Health and Safety
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10）
Safety Measures of Machineries
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11）
Health and Safety in the Workplace
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12）
Emergency Measures
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13）
Considerations for Physically Burdensome Work
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14）
Health and Safety in the Facilities
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15）
Health Management
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4.
Environment
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16）
Environmental Permits and Reports
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17）
Minimization of Environmental Impact (drainage, sludge, exhaust, etc.)
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18）
Water Resources and Biodiversity Conservation
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19）
Reduction in Emission of Greenhouse Gasses and Final Waste
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20）
Management of Chemical Substances Contained in Products
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21）
Environmental Protection Activities
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5.
Fair Trade and Ethics
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22）
Compliance with Applicable Laws
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23）
Establishment of Customer Confidence
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24）
Fair Advertising and Public Relations
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25）
Free and Fair Competition
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26）
Protection of Intellectual Property Rights
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27）
Fair Transactions with Suppliers of Materials and Services
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28）
Prohibition of Corruption and Bribery
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29）
Conflict of Interest
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30）
Regulation of Donations and Political Contributions
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31）
Stand against Antisocial Forces
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32）
Responsible Mineral Procurement
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33）
Compliance with Laws Concerning Import and Export
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34）
Security Trade
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35）
Disclosure of Management Information
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36）
Prohibition of Insider Trading
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37）
Appropriate Accounting Procedure
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38）
Money Laundering/Terrorist Financing
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39）
Prohibition of Private Activity
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40）
Appropriate Use of Corporate Assets
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6.
Quality and Safety
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41）
Product Safety and Quality Assurance
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7.
Information Control
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42）
Control of Trade Secret and Company Secret
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43）
Information Security
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44）
Protection of Personal Information
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8.
Social Contribution
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45）
Social Contribution
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9.
SMK Ethics Helpline
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46）
SMK Ethics Helpline
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10.
Supplementary Provision
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47）
Reference
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48）
Improvement or Amendment of this Code of Conduct
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49）
Penalty
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50）
Submission of Pledge Card
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51）
Enforcement
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SMK Group Anti-Bribery Policy
We, the officers and employees of the SMK Group, will comply with the applicable laws and regulations of each country and work to prevent bribery in order to ensure fair, transparent and free competition.
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1.
We will not engage, directly or indirectly, in any act of bribery (such as offering, promising, requesting or accepting money, goods or services), to any person, including public officials, executives or employees of private companies, to obtain or maintain business advantages or benefits.
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2.
If we make donations or contributions of any kind, we will do so in compliance with the relevant laws and regulations and in a lawful manner, after giving due consideration to the necessity and appropriateness of such donations or contributions.
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3.
We strictly refrain from unethical entertainment or gifts, as these may be considered acts of bribery.
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4.
We will perform accounting procedures in accordance with relevant laws, regulations, and internal rules, and keep accurate records of such procedures.
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5.
The SMK Group shall regularly train its directors, officers, employees, and others on the prevention of bribery.
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6.
The SMK Group will take strict disciplinary action against those involved in bribery in accordance with the Rules of Employment and so on.
SMK Group Anti-Cartel Policy
We, the officers and employees of the SMK Group, will comply with the applicable laws and regulations of each country and work to prevent cartels in order to ensure fair, transparent and free competition.
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1.
We will not enter into agreements, understandings, or exchanges of information with other companies in our industry that may restrict prices, volumes, customers, sales channels, facilities, technology, or entry, or otherwise impede fair and free competition.
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2.
We will exchange information with employees of other companies in our industry at official meetings of trade associations where the conduct described in the preceding article is prohibited.
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3.
When we are in the same room with employees of other companies in our industry at meetings other than official industry association meetings (such as meetings hosted by the customer), we will confirm the purpose of the meeting in advance and will not exchange information about the prohibited activities stipulated in Article 1.
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4.
We will report the contents of the meeting to our supervisors in the minutes and materials prepared by the official meeting secretariat of the above-mentioned organizations and so on.
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5.
The SMK Group will take strict disciplinary action against those involved in cartel activities in accordance with the Rules of Employment and so on.
Legal Compliance Training
We conduct training each year on decided themes for employees whose work is relevant. Furthermore, we have established an e-learning system where past training materials are published on the internal portal for all employees to take courses at any time.
| Theme | Attendance (%) (Among targeted employees) | |
|---|---|---|
| FY2023 | Global Competition Law | 77.1 |
| FY2022 | Revised Act on the Protection of Personal Information of Japan | 78.3 |
| Global Anti-Bribery Laws | 64.7 | |
| FY2021 | Whistle-Blowing System | 87.0 |
Relations with Customers and Suppliers
SMK regularly conducts customer satisfaction surveys for our customers and compliance questionnaires for our suppliers. We incorporate evaluations of our company, as well as valuable opinions and advice on our compliance efforts, into our activities. For more details, please visit the following pages.
Whistle-Blowing System
To ensure the early detection, correction, and prevention of violations of laws and internal regulations, SMK established the SMK Ethics Helpline as an internal whistle-blowing channel in July 2005. We addresses reports and inquiries from employees in accordance with the Whistle Blowing Operation Rules.
Two contact points are available: An internal contact within the Corporate Legal Department and an external contact point at an outside law firm, which allows anonymous reporting. Furthermore, a message from the President is regularly distributed to employees to remind them that this is a secure system. This approach aims to create a system that is easily accessible and effective in practice.
Security Export Control
To maintain international peace and security, SMK complies with the export control related laws and regulations, including the Foreign Exchange and Foreign Trade Law.
Specifically, SMK has established a Security Export Control Committee under the CSR/Sustainability Committee, and established internal rules for Security Export Control. Then we properly determine whether our products are subject to the list-control and confirm the end-users and end-uses as much as possible.