At 918kiss plus Agent, we have established a "Compliance Promotion Committee" underneath the CSR Management Committee chaired by the Representative Director, which deliberates and decides the basic directions concerning revisions to the "Corporate Ethics Policy and Code of Conduct" and the drafting and implementation of dissemination activities. The matters decided by this committee are deployed to the entire Group through persons in charge of promoting compliance appointed at affiliated companies in Japan and overseas.
In addition, a "Compliance Promotion Leader" is selected in each department in order to disseminate the "Corporate Ethics Policy and Code of Conduct" to the employees, and the Promotion Leader conveys the knowledge obtained by taking e-learning courses, etc. to the employees through compliance promotion meetings held in each department.
Moreover, these compliance promotion systems are determined according to the "Compliance Program Rules."
Furthermore, the operational status of the compliance promotion activities and the whistleblowing system (number of cases reported, overview of the reporting details) are reported to the Board of Directors twice a year while also being annually audited by the internal audit to ensure the appropriateness.
At Murata, we continuously inform and educate all Group officers and employees based on the "Corporate Ethics Policy and Code of Conduct." In addition to training provided when joining the company or leaving for a new post in charge of an overseas affiliated company, every year during the month of October, which is designated as the compliance promotion month, we (1) implement group discussions using the case method, (2) conduct compliance verification tests, (3) take compliance attitude surveys, and (4) disseminate compliance information including the distribution of portable cards with compliance reporting and consulting service information. Moreover, each month we issue the "Compliance Magazine" to the employees as part of our efforts to increase employee awareness of violations of corporate ethics and the law such as insider trading, cartels, bribery and information leaks. Within our overseas affiliated companies, the regional management company and each affiliated company implement awareness and educational activities based on the local situation.
In 2020, in order to disseminate the importance of compliance again, the Representative Director sent a message to all Group officers and employees stating that compliance is the foundation of sustainable growth. Moreover, compliance seminars were held for officers and department heads within Japan during which they held group discussions to think about compliance risks that may occur in their own workplaces and how to respond (number of participants: approximately 230 people). Furthermore, during the compliance promotion month, each department head issued compliance messages to their own departmental employees and held the compliance seminars described above (number of participants: approximately 15,500 people).
In order to prevent, achieve early detection, and respond to compliance violations, Murata has introduced a whistleblowing system within 918kiss plus Agent and its domestic and overseas affiliated companies. In the event that acts which violate or may violate the "Corporate Ethics Policy and Code of Conduct", such as cartels or bribery, are discovered, the whistleblower may report or consult about such acts using their real name or anonymously. In addition to establishing an internal compliance hotline within 918kiss plus Agent and its domestic and overseas affiliated companies as a point of contact for receiving reports and consultation requests, we have established external compliance hotline which provides support in local or multiple languages in order to prepare an environment which makes it easier to submit reports and seek consultation. Moreover, employees can also directly report or consult with the Audit and Supervisory Committee which audits and supervises the overall execution of corporate affairs. Employees are informed through the intranet and posters about how to contact and use these hotlines.
In the event that a report or consultation is received, the Compliance Promotion Committee, chairperson of the committee, and the secretariat of the committee, will lead the response. Coordinating with the relevant departments as needed, they verify and investigate the facts of the matter and the relevant laws and rules to the extent possible. Moreover, they will certify whether a compliance violation exists and take measures such as corrective instructions and recurrence prevention measures as needed.
At this time, the privacy of the whistleblower shall be protected in addition to prohibiting reprisals against whistleblower and extending the maximum consideration so that they do not suffer any unfair disadvantages as a result of filing the report. In addition, when reports or consultation requests are made in the whistleblower’s actual name, feedback regarding the status and results of the subsequent verification and investigation shall be provided to the whistleblowers.
During FY 2020, approximately 150 reports and consultation requests were received through the domestic compliance hotlines.
In May 2014, Murata established a "Basic Policy Regarding the Prevention of Cartels and Bribery." Although cartels and bribery are also prohibited in the "Corporate Ethics Policy and Code of Conduct", as a company that develops its business globally, we again disseminated Murata's basic stance on cartels and bribery throughout the Group. This basic policy was developed to the entire Group in Japanese, English, and Chinese.
Link: Basic Policy for Prevention of Cartels and Bribery (PDF: 97KB)
Furthermore, contact with competitors is allowed only when necessary and is subject to a control process which requires prior-approval and post-reporting. This control process has been established across the entire Group. In addition to creating and disseminating guidelines describing the rules and procedures for this control process, we perform periodic monitoring to verify the operational status of the control process. Reporting and other internal procedures when entertaining or exchanging gifts has also been deployed across the entire Group.
To ensure a thorough awareness of the "Basic Policy for Prevention of Cartels and Bribery," rules, and procedures, we implement training and provide education such as annual e-learning in Japanese and English for participants in Japan.
In addition to these e-learning sessions, in the area of cartel prevention, we are periodically conducting practical training including case studies, and in the area of bribery prevention, we are working to increase the awareness of the employees by expanding the scope of coverage of training and conducting new e-learning program for each employee level.