Compliance

Zeon Corporation will not merely comply with laws and regulations. We will act with integrity based on the values and ethics expected of corporate and social citizens, realize fair and appropriate management through such conduct, and seek harmony with local communities and society.

The Compliance Committee has been established under the umbrella of the CSR Conference (chaired by the representative director), our highest decision-making body regarding CSR. The Compliance Committee deliberates and decides on compliance-related activities and various measures, receives progress reports, and issues necessary instructions.
The Compliance Committee also has three subcommittees, namely the Anti-trust Law Regulatory Subcommittee, the Export Security Control Subcommittee, and the Corporate Governance Subcommittee, which promote initiatives such as preventing violations of the Antimonopoly Law.

Based on the Sustainability Policy, Zeon Corporation strives to prevent corruption through implementation of the Sustainability and CSR Basic Policy as well as the CSR Code of Conduct, Policy on Prevention of Bribery, Guidelines for the Prevention of Bribery of Foreign Public Officials and Others, the Subcontract Act Compliance Rules, the Insider Trading and Timely Disclosure Management Regulations and the Anti-trust Law Compliance Guidelines among others.
These various rules under the Sustainability and CSR Basic Policy are regularly revised every three years, based on Group-wide rule management regulations.
The CSR Code of Conduct applies to all Zeon Group companies both in Japan and globally and shares Zeon’s compliance approach and initiatives.
In addition, to help ensure that compliance activities are conducted, the “Compliance Text Q&A” has been compiled and released on the intranet system. This information is organized and shared so that employees can confirm how to respond to specific incidents.
Furthermore, to deepen understanding of compliance and promote the incorporation of this understanding into business processes, employees in senior management roles and above are requested to submit a CSR pledge every year.
Meanwhile, persons who engage in fraudulent acts are subject to appropriate disciplinary measures based on Zeon rules including the Employment Rules.

We provide compliance education to all employees, including anti-corruption measures based on the “Zeon Group’s Policy on Prevention of Bribery” and the prevention of harassment, covering compliance as a whole.
In addition to continuing conventional training programs such as e-learning–based compliance education and legal seminars conducted in an online meeting format, we are strengthening practical education and training to help employees better understand compliance as a personal responsibility. Specifically, we conduct workshops on fraud prevention for managers and workshops on the prevention of quality misconduct for factory quality assurance personnel, thereby enhancing practical response capabilities based on risks that may arise in the workplace.

Zeon Corporation supports the principles of the United Nations Global Compact and is working against corruption in all its forms, including extortion and bribery, striving to prevent conflict-of-interest transactions, anti-competitive behavior, insider trading, and other similar violations.

Furthermore, we prohibit offering, proposing, or promising improper entertainment, gifts, benefits, or other advantages to foreign public officials and others in accordance with the Zeon Group’s Policy on Prevention of Bribery and the Guidelines for the Prevention of Bribery of Foreign Public Officials and Others.
Only when there is no improper intent and the act is deemed appropriate in light of internal rules, applicable laws and regulations, and social norms, entertainment and similar activities may be conducted in accordance with the Guidelines on Providing Advantages to Foreign Public Officials, and any expenses incurred are accurately reflected in the accounting records.
In addition, when engaging agents, consultants, and other similar parties, we ensure that payments are not used, with improper intent, to provide advantages including entertainment, gifts, and benefits to foreign public officials and others. Especially for those in countries and regions with high corruption risk where the Transparency International Corruption Perceptions Index score is below our internal threshold, we scrutinize, in advance, their identity, business activities, relationships with foreign public officials and others, and other relevant aspects in accordance with the Guidelines on the Engagement of Agents, Consultants, and Other Similar Parties and examine whether to engage with them as well as the appropriateness of the services and remuneration. We are also promoting the expansion of these initiatives to group companies in Japan and overseas.

In FY2024, there were no cases detected or fines or settlement payments paid in relation to corrupt practices. There were also no cases of dismissal or disciplinary action due to violations of anti-corruption policies.

We report on the status of our compliance activities, including anti-corruption measures, to the Board of Directors and are subject to its oversight.