Compliance
Communication of our basic social responsibilities
We have declared our commitment to thorough compliance in AISIN Group Principles of Corporate Behavior. We have also formulated and communicated to all employees the Guidelines in Compliance with Social Responsibility to put the philosophy underpinning these principles into practice. The president himself is leading our efforts to reinforce compliance.
Furthermore, in concert with the revision of the AISIN Group Principles of Corporate Behavior, we strive to communicate them to all employees, having prepared a take-along AISIN Group Principles of Corporate Behavior card and distributed it to all employees, and having enabled all employees to confirm the Principles at any time on our website.
Basic stance
Aisin believes that compliance is not only about following laws and regulations but about meeting people‘s expectations and earning their trust as a good corporate citizen from the perspective of Inspiring “Movement,” Creating Tomorrow, a corporate principle of ours.
We are carrying out extensive group-wide initiatives around the world to ensure that everyone in AISIN Group shares the same strong sense of ethics regarding acting honestly, fairly and in good faith, and that compliance is their default state of mind.
AISIN Group compliance framework
Aisin has established a Consolidated Business Ethics Committee to make decisions about important policies and frameworks regarding compliance in the group. In January 2018, we established a legal affairs division at the AISIN Group Head Office, bringing together all departments involved in legal affairs to ensure that the whole of AISIN Group meets or exceeds a particular level of compliance. Acting as the group‘s only specialist legal affairs division, this division plans and implements global group compliance activities.
Organizational diagram of Business Ethics Committee
Messages from top management and executives
Our top management and executives’ mindsets about compliance are disseminated through activities such as distributing a video where the Chair of our Business Ethics Committee (Executive Vice President) says “Compliance is about proactively meeting the expectations of all of our stakeholders“ and posting declarations about compliance from all executives and department presidents in our group companies in our workplaces.
Activities to raise awareness of compliance
Guidelines in Compliance with Social Responsibility
Aisin has formulated guidelines in compliance with social responsibility to provide concrete behavioral standards for all domestic and overseas employees.
The action guidelines contain questions and answers about the nine principles outlined in AISIN Group Principles of Corporate Behavior: Safety, Quality and Contribution to the Creation of a Sustainable Society; Compliance; Disclosure and Communication; Respect for Human Rights; Promotion of Diversified Work Styles and Upgrading of Work Environment; Environment; Social Engagement and Contribution to Development; Thorough Crisis Management; and Company Leadership. Q&A are outlined for each principle with easyto- understand explanations, and the guidelines are designed to reflect the spirit of AISIN Group Principles of Corporate Behavior. We also distribute cards with the AISIN Group Principles of Corporate Behavior for employees to carry, post information on our website and provide training to communicate and thoroughly entrench this knowledge.
Various training and awareness-raising activities
Aisin carries out various training and awareness-raising activities so that compliance is the default state of mind for every employee.
Training takes the form of group training and e-learning for each level, role and area of work, both in Japan and overseas. In fiscal year 2021, a total of 12,887 domestic employees attended training by our legal affairs department. Additionally, compliance enforcement personnel from each department play a role in communication about compliance in their workplaces to entrench our compliance policies among all employees. In fiscal year 2021, to ensure that our activities are carried out honestly, fairly, impartially and in good faith, we strengthened our regulations against insider trading, one of the company‘s Critical Risks, and revised and internally disseminated our rules about advance notifications in the event of a critical rollout or trading of our own shares.
We carry out awareness-raising activities such as providing the latest information in our monthly reports and distributing discussion sheets about relevant examples.
List of training and awareness-raising activities
| Category | Training/tool | Executives | Management | Employees | Main details | |
|---|---|---|---|---|---|---|
| Education | Specific levels | Training for new executives | ○ | Responsibilities and key themes for executives | ||
| Compliance seminars for executives | ○ | Latest compliance topics | ||||
| CSR management training | ○ | The importance of compliance | ||||
| Training for new plant managers | ○ | The importance of compliance; roles | ||||
| Training for new hires | ○ | ○ | Basic compliance, charters, codes of conduct | |||
| Specific roles | Training for compliance enforcement personnel in each department | ○ | Roles and key themes for enforcement personnel | |||
| Pre-departure training for employees posted overseas | ○ | ○ | ○ | The importance of compliance and key themes | ||
| Training for top management overseas | ○ | ○ | The importance of compliance and key themes | |||
| Training for whistleblowing service personnel | ○ | ○ | Investigation methods and points of caution | |||
| Specific themes | Antitrust compliance training | ○ | ○ | Laws, company policies, guides | ||
| Anti-corruption training | ○ | ○ | Laws, company policies, guides | |||
| Training on prevention of insider training | ○ | ○ | Laws and company rules | |||
| Export management training | ○ | ○ | Internal qualification training | |||
| Awarenessraising | Texts | Monthly legal reports from Group Head Office | ○ | ○ | ○ | Latest/key compliance topics |
| Comics | Workplace discussion sheets (monthly) | ○ | ○ | ○ | Explanations and points of caution for specific themes | |
Main points in training
- ・Antimonopoly Act
- ・Harassment
- ・Regulations against insider trading
- ・Clear communication
- ・Act Against Delay in ‘Payment, etc.‘ to Subcontractors
- ・Fraud
- ・Responsibilities for manufactured products
- ・Labor
- ・Prevention of bribery and corruption
- ・Copyrights
- ・Export trading management
- ・Contracts
etc.
Awareness surveys
October of each year is Aisin’s Business Ethics Campaign Month. One activity carried out in this month is a survey of all domestic employees in the group to confirm points such as their awareness of compliance and ethics consultation services (77,242 respondents).
In the survey conducted in fiscal year 2021, 96.2% said that their awareness of compliance had improved and 95.3% said they knew about ethics consultation services, a high rate for both.
In addition to reporting the results at a meeting attended by our top management, feedback is given to each company and department. The survey results are included in the next fiscal year‘s compliance activity plan and PDCA cycles are carried out.
Early detection and correction of issues through whistleblowing system
Aisin has a service for reporting and questions about compliance. The service is available to all employees in AISIN Group and people connected to them, such as family members and trading partners. Anonymous contact is accepted. We endeavor to detect and correct violations as quickly as possible with this service. Thorough attention is paid to the rights of whistleblowers, including privacy and prevention of reprisal, when taking measures.
We have also established an internal consultation service, a group-wide external consultation service by a lawyer, a consultation service handled by the legal affairs division at AISIN Group’s headquarters and an AISIN Global Hotline. All domestic and overseas stakeholders, including executives, employees and trading partners, can report incidents or ask questions to the service that best suits their situation. In addition to ensuring that these services are easy to use, the legal affairs division in our Group Head Office takes the lead in responding to critical situations to ensure that issues are detected quickly and corrective action is taken.
Domestic and overseas reports and consultations
| Reports and consultations | Cases |
|---|---|
| Other* | 396 |
| Hostile workplace | 145 |
| Fraud and rule violations | 139 |
| Abuse of power | 105 |
| Issues with work hours, etc. | 56 |
| Sexual harassment | 9 |
| Total | 850 |
FY2021 850
*Other main cases include inquiries about internal rules and procedures and concerned about working relationships. While these are not reports concerning compliance or fraud, we work with the relevant departments to resolve these issues so that we can eliminate these points of concern and improve these employees‘ working conditions.
Aisin Global Hotline
AISIN Group also has a reporting system which enables external stakeholders to report any concerns related to AISIN Group’s compliance.
1. Contents that can be Consulted and Reported
Any behavior or act by the officers and employees of AISIN Group that violates AISIN Group’s compliance polices, including, but not limited to, the following:
- ・AISIN Group Principles of Corporate Behavior
- ・Guidelines in Compliance with Social Responsibility
- ・AISIN Group Human Rights Policy
＜Contents that cannot be Consulted and Reported＞
- ・Items intended for slander or libel against others
- ・Fake reports
2. Target User of this Hotline
Suppliers and customers which are in a business relationship with AISIN Group, as well as anybody of the general public
3. Method and Flow of Consultation and Report
Consultations and Reports can be made via web input by providing identity or under anonymity. For more proper investigation, we ask the whistleblower to provide as precise as possible the facts concerning the consultation and report (e.g., when/where/how it happened, who is involved, what are the concerns, how whistleblower become aware about it).
The flow of consultation and report is as follows.
The acceptance of consultation and report through Aisin Global Hotline is conducted by an independent, trustworthy third-party organization, NAVEX Global, Inc. Contractual confidentiality is imposed on NAVEX Global, Inc., so please feel reassured to consult and report.
4. Other Notification about Consultation and Report
- ・The facts and contents of the consultation and report, as well as the information provided by the whistleblowers to this Hotline, will be used only for the purpose of investigation, and will be strictly kept confidential within the parties involved in such investigation. Without the consent of the whistleblower, such information will not be used for purposes other than as mentioned above, and will not be disclosed to third parties other than the above-mentioned parties involved in the investigation.
- ・Retaliation due to the fact that a consultation or report was made via this Hotline is prohibited.
- ・We take the consultations and reports from the whistleblowers seriously, and will review and conduct any necessary investigation.
- ・Please do not divert or secondarily use a part or all of the communication received from this Hotline.
Handling of main areas of compliance activities
As AISIN Group‘s business expands globally, we are carrying out initiatives in the following key areas.
Anti-Corruption Initiatives
The AISIN Group has declared in its Principles of Corporate Behavior that it builds healthy and proper relationships with the government and administration, and never has any relationship with antisocial forces or organizations.
Furthermore, the AISIN Group regards anti-corruption as priority area in compliance, and established the AISIN Group Anti-Corruption Policy common to the AISIN Group in April 2020, based on Principles of Corporate Behavior. This policy clearly states that the AISIN Group prohibits bribery, corruption, inappropriate entertainment and gifts, and carries out proper accounting processing, which has been distributed to domestic and overseas group companies. We are also working on compliance with the policy while maintaining guidelines for concrete actions.
Anti-corruption training is carried out actively at every location and level. Some areas where this takes place are 1) a topic in our compliance training for new directors in domestic group companies, 2) a topic in our stratified training in our main domestic group companies, 3) a topic in our compliance officer training in each department of our domestic group companies and, 4) a topic in our training prior to transfer for members of major domestic group companies to be transferred to overseas companies, and 5) a topic in our top management training for top managers and department managers Aisin Seiki's overseas sub-consolidated companies. Each department assesses the risk of corruption where necessary, using a risk assessment sheet.
We are making efforts to prevent corruption: When starting business with a new business partner, we conclude a basic agreement specifies that (1) both parties will comply with regulations concerning the prohibition of bribery that apply inside and outside Japan, and (2) both parties will not provide money or other benefits to third parties, including public servants, as compensation for an act of dishonesty, and (3) check whether the relevant partner company has received any directive from a public body or similar organization on suspicion of a violation of anti-bribery regulations and whether it has anti-bribery rules and frameworks in place. Also, at the time of business restructuring, etc., to confirm that relevant companies comply with laws and regulations, as required items, we check about violations not only acts concerning economy, including the anti-monopoly act and subcontracting act, but also criminal offenses, including bribery.
In terms of risk management, we carry out evaluation regarding risks, including dishonest acts of executive and staff members, illegal taking out of corporate property, bribery and other corruptive acts, through the global risk management structure, and conduct risk management activities based on the result of the evaluation.
The AISIN Group intends to address any corruption with fines, penalties and/or termination of employment in FY2019.
Initiatives to comply with the anti-monopoly act
The AISIN Group has declared in its Principles of Corporate Behavior that it is committed to fair, transparent and open competition and appropriate and responsible business. Furthermore, the AISIN Group regards compliance with the Anti-monopoly Act as priority area in compliance as well as the anti-corruption, and established the AISIN Group Antitrust Compliance Policy in April 2020, based on Principles of Corporate Behavior. We are also working on compliance with the policy while maintaining guidelines for concrete actions.
In Japan, we are making efforts to have all employees develop an awareness and understanding of compliance with the anti-monopoly act by providing a wide range of education, including workplace manager training, training at the time of promotion for members including executives, and E-learning training. We also provide training prior to transfer for members to be transferred to overseas companies, and in overseas companies, we provide training according to the risks of each region.
Furthermore, we are making efforts to comply with the anti-monopoly act, including prior and post checking using specified forms and screening before contacting our competitors.
Export management
To ensure that we comply with all relevant laws and regulations regarding export management, we establish and roll out groupwide resources such as regulations for safe and secure export management and an export management manual. We have also introduced qualifications for export managers who receive training from the legal affairs division of our group head office to ensure all export managers meet the appropriate level. In Japan, we use our group-wide export management system to ensure that trades involving exports are carried out effectively and efficiently.