Compliance

Zeon Corporation goes beyond mere compliance with laws and regulations. We act with integrity, guided by the values and ethics expected of us as business people and as members of society; pursue fair and appropriate management through such conduct; and seek harmony with local communities and society.

The Company maintains the Legal and Compliance Division, which is responsible for planning, formulating, and promoting compliance-related activities and various measures. The Legal and Compliance Division also advances initiatives such as the prevention of violations of the Antimonopoly Law and the promotion of security export controls.

Based on the Sustainability Policy, Zeon Corporation has enacted the Sustainability and CSR Basic Regulations, together with the CSR Code of Conduct, the Rules for the Prevention of Bribery of Public Officials and Others, the Rules for the Prevention of Bribery of Foreign Public Officials and Others, the Compliance Rules for the Act on the Protection of Contractors in Manufacturing and Service Outsourcing (the former Subcontract Act), the Insider Trading and Timely Disclosure Management Regulations and the Antimonopoly Act Compliance Rules, among others. These rules under the Sustainability and CSR Basic Regulations are reviewed once every three years in accordance with the Company Rules Management Regulations. The CSR Code of Conduct applies to all Zeon Group companies in Japan and overseas and communicates Zeon’s approach to compliance and related initiatives. To support compliance activities, the “Compliance Text Q&A” has been compiled and published on the intranet so that employees can confirm how to respond to specific situations. To deepen understanding of compliance and integrate it into business processes, employees in senior management roles and above must submit a CSR pledge annually. Individuals who engage in fraudulent conduct are subject to appropriate disciplinary measures under Zeon rules, including the Employment Rules.

We provide all employees with education on compliance as a whole, beginning with anti-corruption based on the “Zeon Group’s Policy on Prevention of Bribery” and extending to the prevention of harassment.
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 works to combat corruption in all its forms, including extortion and bribery. We seek to prevent conflicts of interest, anticompetitive conduct, insider trading, and similar violations. We also prohibit the provision of, the offer of, or any promise of improper entertainment, gifts, benefits, or other advantages to foreign public officials and related parties 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. Entertainment and similar activities may be provided only when there is no improper intent and the activity is appropriate under internal rules, applicable laws and regulations, and social norms. Such activities must comply with the Guidelines on Providing Advantages to Foreign Public Officials, and all related expenses must be accurately recorded. When engaging agents, consultants, or similar parties, we ensure that payments are not used with improper intent to provide entertainment, gifts, benefits, or other advantages to foreign public officials and related parties. For parties in countries or regions with a high corruption risk—where the Transparency International Corruption Perceptions Index score falls below our internal threshold—we conduct advance scrutiny of their identity, business activities, relationships with foreign public officials, and other relevant matters under the Guidelines on the Engagement of Agents, Consultants, and Other Similar Parties. We also assess whether to engage them and whether their services and remuneration are appropriate. These initiatives are being implemented across Group companies in Japan and overseas. In FY2025, Zeon was not subject to any enforcement action in relation to corrupt practices, nor did it pay any fines or settlements. No employees were dismissed or disciplined for violations of anti-corruption policies.

We report the status of our compliance activities, including anti-corruption measures, to the Board of Directors, which oversees these activities.