Compliance
Basic Approach to compliance
As a member of the NAGASE Group, we share the Group’s management philosophy of maintaining the highest integrity as a member of society, and we regard compliance with laws, regulations, and internal rules as the foundation of our corporate activities. In response to growing expectations for corporate social responsibility (CSR), we emphasize sincere and transparent conduct to earn the trust of society.
The NAGASE Group formulated the Basic Compliance Policy in 2002, followed by the NAGASE Group Code of Conduct for Compliance and the Compliance Consultation and Whistleblowing Regulations in 2003. In 2024, these policies were revised into the Code of Conduct for Risk Management & Compliance, incorporating a risk management perspective to further strengthen the group-wide compliance framework. In addition, the NAGASE Group established the NAGASE Group Product Safety Principles to promote the provision of products that comply with laws and regulations both in Japan and overseas.
Building on these Group policies, we have established our own initiatives, the NCX Crisis Management Regulations, which were revised in 2024. These regulations enable us to detect early signs of compliance violations or management risks and respond swiftly and appropriately.
We are committed to fostering a corporate culture that values compliance, aiming for sustainable growth and earning the continued trust of our stakeholders.
The Code of Conduct for Risk Management & Compliance
Based on our management policy that “We recognize our responsibility to society and offer beneficial products and services while maintaining the highest standards of integrity. Through our growth, we will contribute to society and enrich the lives of our employees.”, We hereby establish and execute the Code of Conduct for Risk Management ＆ Compliance as follows.
This Code of Conduct defines the behavior standards that the NAGASE Group and its officers and employees will observe as they carry out their work.
We require our officers and employees to comply with these standards and team them to others by example—particularly to co-workers. Any danger of non-compliance must be addressed without delay, and officers or employees should identify the root cause of the issue, taking steps to prevent any recurrence.
Comply with applicable laws and regulations; conform to internal rules
Conduct business fairly and in good faith, in keeping with laws, company rules and social norms.
Conduct work in keeping with internationally accepted norms to ensure our growth as a global enterprise.
Comply strictly with domestic and foreign laws including laws regarding bribery and competition laws.
Eliminate anti-social elements
We firmly reject any anti-social elements that threaten the public order and safety.
Provide useful products and services
Contribute to society through useful goods and services.
Respecting the Rights of people Involved in the Business
We foster a corporate culture in which employees can contribute with their independence and creativity.
We respect the rights of our employees as well as all of those who are involved in the NAGASE Group’s supply chain and business activities, and those who contribute to the realization of a sustainable economy and society.
Disclose information
We will ensure management transparency by fairly disclosing corporate information to our stakeholders, including our customers, suppliers, employees, and shareholders.
Protect the global environment
We recognize and perform on our responsibility to improve the environment.
Risk Management
the NAGASE Group will promote risk management to achieve stable business continuity and sustainable growth, in a rational and optimal manner, by managing risks that may become barriers to the management of the NAGASE Group.
Responsibilities to top management
The top management of all the NAGASE Group members including NAGASE & CO., LTD.., Ltd. shall take the lead to ensure that the business is administered “with the highest standard of dignity as a member of society”.
Compliance initiatives
Risk and Compliance Penetration Activities
The NAGASE Group Risk and Compliance Manual is distributed to all employees to disseminate the Introduction to the Code of Conduct for Risk Management & Compliance and the compliance consultation and reporting service (Compliance Hotline). In addition, the Compliance Consultation and Reporting Office is open to all employees of the Group. We also distribute a card with the contact information of the Compliance Hotline to all employees.
We regularly conduct educational programs on compliance for our officers and employees.
Compliance Consultation and Reporting Desk
Nagase ChemteX has a Compliance Consultation and Reporting Desk, where officers and employees can directly contact and report on the premise of confidentiality and anonymity.
- There are no restrictions on the types of cases that can be discussed or reported. We accept reports on various issues, including harassment, human rights violations, and corrupt practices, such as bribery.
- In addition to the internal contact point, the NAGASE Group has a common contact point at the head office and a designated law firm for consultation and reporting.
- Consultation and reporting can be done in writing, by telephone and email.
- Measures are taken to ensure that no disadvantageous treatment is given to those who consult or report. Furthermore, we take great care to maintain the confidentiality of consultations and reports and prevent the identification of consulters and reporters.
Reporting the status of compliance
We appropriately operate an internal reporting system and conduct periodic internal audits to check for violations of laws, regulations, and internal rules stipulated in the Code of Conduct for Risk Management & Compliance. In particular, we conduct annual internal audits of our Company for security trade control and product law control. If the results of an internal audit indicate that a more detailed investigation is necessary, the Risk Management and Compliance Committee will establish an investigation team to conduct the investigation while respecting the credibility, honor, and privacy of those involved. If any violation of laws and regulations or internal regulations is found as a result of the investigation, corrective measures and preventive measures will be taken immediately, and appropriate measures such as internal measures will be taken if necessary. In addition, we will report to the relevant administrative agencies, etc. if necessary, and if the Risk Management and Compliance Committee deems it necessary, we will disclose the information outside the company.
The NAGASE Group regularly reviews the effectiveness of its Code of Conduct and Code of Ethics.
Fair Business Practice Initiatives
With regard to anti-monopoly laws and global competition laws and regulations, we are actively conducting educational activities for the NAGASE Group’s major manufacturing companies and other companies, focusing on cartel regulations that have a large impact in terms of monetary penalties. We will continue to promote awareness of fair trade related laws and regulations within the group, focusing on those that are highly necessary. In addition, in view of the strengthening of the use of anti-bribery prevention measures for foreign public officials in the Unfair Competition Prevention Law and the overseas application of anti-bribery prevention regulations such as the FCPA in the U.S. and UKBA in the U.K., we will continue to conduct educational activities on anti-bribery prevention regulations targeting groups in Japan and overseas.
Anti-Corruption Approach
Anti-Corruption Approach
We strive to prevent all forms of corruption and maintain sound and proper relationships with business partners and government authorities, based on the NAGASE Group’s approach to anti-corruption.
The NAGASE Group Basic Approach to Preventing CorruptionInternal and external communication and training on anti-corruption
In its Introduction to the Code of Conduct for Risk Management & Compliance, the NAGASE Group declares strict compliance with domestic and foreign laws and regulations, including bribery and competition laws, and stipulates rules for compliance with laws and regulations and maintaining sound and normal relationships with business partners and the government. This Introduction to the Code of Conduct for Risk Management & Compliance and the Code of Conduct for Risk Management & Compliance are posted on the NAGASE Group’s internal intranet and external website to ensure that all Group employees are fully aware of the policies, and compliance survey are conducted on a regular basis.
Compliance training for all Group employees (including temporary employees and commissioned employees) covers a comprehensive range of anti-corruption issues, including harassment, bribery, accounting fraud, improper payments, cartels (bid-rigging), and data security.