SII Compliance System

As our CSR committee carries the function of compliance, it has been working on raising compliance awareness and responding to each compliance problem.

Based on the Internal Control Basic Policy, we continue to reinforce and improve the compliance framework of subsidiary companies in the world.
At the overseas subsidiary companies, their appointed compliance coordinators are promoting activities to enhance the compliance framework.

SII Code of Conduct

To act in accordance with the SII Group Charter of Corporate Behavior, SII established the "SII Code of Conduct," defining the basic requirements that all the SII Group directors and employees need to comply with. We continue to conduct the SII Code of Conduct thoroughly at all sites in the world.

The "Action Guidelines" was also established for sites in Japan to provide a specific and detailed code of behavior. Currently we are preparing the Action Guidelines for overseas subsidiaries.

SII Code of Conduct

Compliance Consultation Services

The SII Helpline has been set up for consultation with an outside attorney upon discovery of a violation of compliance.

The SII Helpline is available to former employees of SII Group and its companies as well as its business partners to provide information on non-compliant activities of the SII Group. We have also established an internal consultation service.
The contents of the reports and consultations are immediately reported to the Chairman of the CSR Committee and the Corporate Auditors, and also to the CSR Committee and the Board of Directors on a regular basis.

There were eight reports and consultations in the SII Group in FY 2019.

Compliance Education

In order to fully enforce the compliance with each senior management and employee, the SII Group executives and employees participated in an online quiz education program again in FY 2018.

We also continued to provide new employees, newly-appointed management, and senior management with compliance training aimed at raising awareness, as well as visiting units and affiliated companies to conduct compliance training on a regular basis.

Furthermore, the management at the head office have expanded compliance training to include subsidiaries outside Japan, and in 2019 compliance training was carried out at such a site. Managers including department heads participated and reaffirmed the importance of compliance.

Compliance Awareness Survey

SII continually conducts compliance awareness surveys to check how much the SII Group employees' compliance awareness has been raised and entrenched. The FY 2019 result is as follows.

Results of the FY 2019 Compliance Awareness Survey

Survey Period: June 17 through July 19, 2019
Target: Employees and executives of SII and its affiliated companies in Japan
No. of Respondents: 2,241 (2,389 in FY 2018)

Q1 Do you always bear in mind the laws and rules concerning your operations when you are working?

Compliance Awareness Survey

Total may not become 100% due to rounding off.

Q2 Does everyone in your division or department fully understand the importance of compliance with laws and rules?

Compliance Awareness Survey

Total may not become 100% due to rounding off.

Export Control

To ensure international security and to practice an appropriate export control, we established an internal system to provide regular export control education and conduct audits. In FY 2019, we have continued to provide intranet-based education.
In addition, Tokyo Customs has acknowledged the excellence of compliance system and security management carried out at SII; the company is approved as “authorized exporter” on the basis of Authorized Exporters’ Program.