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.
Compliance principles
AISIN Group 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 harmony with society and nature, 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 Group 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 Consolidated Business Ethics Committee*
*As of the end of FY 2020
Activities to raise awareness of compliance
To ensure that compliance is the default state of mind for every employee in AISIN Group, we are using initiatives such as group training and e-learning to ensure that every employee around the world has access to compliance training. We also distribute workplace discussion sheets with specific topics and publish a monthly compliance report to raise awareness of compliance. Our domestic group companies are surveyed about their awareness of compliance.
AISIN Group carries out three main types of training to ensure that everyone from top management to employees is aware of compliance. These are level-specific training, rolespecific training and topic-specific training. Level-specific training is training for new directors, newly promoted personnel and new employees that contains content on compliance. A compliance seminar is held every year for all of the Japan-based directors in the group. Outside experts are invited to give talks on the latest trends related to compliance or topics chosen based on AISIN Group’s situation, so that directors can lead by example. Role-specific training includes training given to personnel who are about to transfer to an overseas post and training for heads of division and higher levels of management in overseas companies. Annual compliance training is also given to compliance enforcement personnel in each department of domestic group companies. 745 people attended this training in fiscal year 2020. Enforcement personnel carry out departmental training and awareness-raising activities about compliance on a day to day basis.
Our awareness surveys are conducted every October during AISIN Group Business Ethics Campaign Month, as part of our activities to raise awareness of compliance. All employees at our domestic group companies are surveyed (78,936 respondents in fiscal year 2020) about their awareness of a wide range of points regarding compliance. The results for fiscal year 2020 indicated that 96.3% of employees had a high (improved) awareness of compliance and 91.3% would take appropriate action in the event of a compliance violation, such as cautioning the offender or reporting them to a supervisor. Improvement activities based on these results were incorporated into our compliance activity plan for fiscal year 2021 and have been put into action.
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.
Early detection and correction of issues through whistleblowing system
AISIN Group has a service for reporting and questions about compliance. The service is available to everyone who works for AISIN Group and people connected to them, such as family members. 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.
In Japan, there are three services to suit different purposes: an internal reporting service within each company, a groupwide external reporting service handled by an attorney and a service handled by the legal affairs division in our Group Head Office. The legal affairs division in our Group Head Office is involved as appropriate to ensure early detection and correction of issues.
Similar whistleblowing services are being set up overseas, and sites in other Asian countries and North America are able to use the main group service.
| Report/request for advice | Cases |
|---|---|
| Abuses of power | 41 |
| Issues related to work hours | 14 |
| Grievance with working conditions | 4 |
| Sexual harassment | 7 |
| Workplace bullying | 5 |
| Foul play/violation of rules | 18 |
| Other | 5 |
| Total | 94 |
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.