Compliance
Compliance
Within the Kirin Group, we define compliance as "fulfilling both legal and ethical responsibilities that society expects from us by adhering to laws, internal and external regulations and rules, and social norms, so that the Kirin Group can avoid the risk of suffering unexpected financial loss or of destroying its credibility and can retain and strengthen the trust of stakeholders." Group Risk and Compliance Committee promotes and manages Group-wide compliance activities, while each Group company integrates compliance activities into Risk management processes to ensure effective implementation.
In addition, internal audit departments conduct audits of legal compliance and related risks, as well as compliance systems and initiatives, which are used to review improvement measures.
Compliance Policy / Compliance Guidelines
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An internal material to raise awareness about "Compliance Guidelines"
"Group Compliance Policy" sets forth the fundamental concepts and behaviors that are legally and ethically required of executives and employees in order to implement the Kirin Group's Corporate Philosophy, Vision and Values. For more specific actions, we have prepared "Compliance Guidelines" and educational tools according to the characteristics of each country and business, and are working to disseminate them. In Japan, we have created "The Rule" as a tool to raise awareness and disseminate it to all executives and employees to ensure thorough compliance.
In addition, the "Group Compliance Policy" and "Compliance Guidelines" are regularly reviewed every year to ensure their effectiveness, while keeping in mind the requirements of the UN Global Compact, the OECD, and other social changes.
Compliance training program
The Kirin Group conducts compliance training every year for all executives and employees, including contract employees and temps in Japan. We aim to help them understand the basics of compliance, such as "compliance is not someone else's problem," "bad information should be reported promptly and accurately," and "act openly and fairly," and to develop sensitivity to changes in society through the training.
In addition, the Kirin Group has established various whistle-blowing systems (see the below section on "Hotline"). We make people aware through compliance training and other activities that reporting to the hotline is for the purpose of improving the company by detecting and responding to the seeds of injustice at an early stage, thereby improving awareness of the hotline and creating an environment where it is easy to report.
In overseas, education and training activities are conducted in accordance with the unique circumstances of each region.
We also conduct an annual compliance and human rights awareness survey mainly for Group companies in Japan to confirm the degree of penetration of compliance, and to investigate and take appropriate measures to improve any comments that appear to be problematic.
Providing hotlines
The Kirin Group has established an internal hotline for reporting compliance violations, corrupt practices, human rights issues (including harassment, etc.), and other acts that violate (or may violate) the Compliance Policy and Compliance Guidelines, with the aim of preventing serious problems associated with corporate activities.
In Japan, we have an internal hotline manned by Kirin staffers, as well as an external hotline with a third-party consultant. In overseas Group companies, we have a global hotline that allows employees of overseas Group companies to report to Kirin Holdings in the language they use locally, in addition to the hotlines at each company.
Both Japanese and global hotlines are posted on each Group company's intranet, etc., and they are made known to employees through annual compliance training sessions and other means.
In addition, we have established the " Rules for the Establishment and Operation of the Internal Hotline", including the acceptance of anonymous reports, the protection of information on whistleblowers and those cooperating in investigations, the prohibition of disadvantageous treatment due to reporting, and other rules.
In order to improve the effectiveness of the hotline, we conduct a survey every year on the willingness and the level of awareness of the hotline among the employees. In addition to receiving reports of violations, the hotline also accepts opinions and questions about matters related to the internal reporting system. Through these efforts, we have established a framework to improve the operation of the hotline by listening to the opinions of employees who utilize the hotline.
Furthermore, we have established a hotline directly accessible to Standing Audit & Supervisory Board Members as well as to compliance officers so that investigations, etc. can proceed independently in cases where the involvement of executives from Kirin Holdings and Kirin Group companies is suspected.
Overall image
In addition to the usual lines through the job system, multiple lines are secured, and in order to avoid accessibility problems due to technical and economic reasons, we support various means of reporting (digital and analog), such as telephone calls, e-mail, application forms, and letters, to provide an environment where users can report 24 hours a day, 365 days a year according to their wishes.
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How Hotlines Work
The following is the general procedure for handling whistleblower reports received via the hotline.
- A whistleblower reports an incident (anonymity is guaranteed).
- Prompt notification of receipt shall be made after receipt of the report.
- After confirming the content of the report, a decision on whether or not to conduct an investigation shall be made generally within 20 days of receipt of such report, and the whistleblower shall then be notified.
- Fact-finding and investigation shall be conducted.
- Information on the method and progress of the investigation shall be shared as appropriate in a manner that does not interfere with the progress of the investigation or with the privacy of the subject of the investigation.
- In case of serious violations as a result of the investigation, disciplinary action shall be considered.
- Feedback on survey results to be provided.
- Feedback of the results of the investigation shall be conducted in a manner that does not interfere with the privacy of the subject of the
investigation. - Prevention of retaliation, including confirmation that the whistleblower has not been treated disadvantageously because of his or her report.
- Feedback of the results of the investigation shall be conducted in a manner that does not interfere with the privacy of the subject of the
Number of calls to the hotlines in the Kirin Group
The number of whitsle-blowing reports to the hotline in the Group over the past three years is shown below.Approximately 70% are related to harassment and human relations in the workplace, and we conduct investigations, interviews, etc., on those cases that have been reported.
| Types of whistle-blowering reports | 2021 | 2022 | 2023 |
|---|---|---|---|
| Harassment | 45 | 61 | 42 |
| Labor affairs and human capital evaluation | 12 | 16 | 13 |
| Workplace environment and human relations | 15 | 9 | 24 |
| Violation of laws and rules | 10 | 3 | 4 |
| Other | 5 | 6 | 15 |
| Total | 87 | 95 | 98 |
Anti-corruption initiatives
The Group fully understands and complies with the laws and guidelines of the countries and regions where it operates and does not tolerate, directly or indirectly, any involvement in corrupt practices* at any time. Kirin Holdings and each Group company has established systems and initiatives based on this strong commitment.
- Corrupt practices refer to any act of abusing authority to gain an unfair advantage, including bribery, facilitation payments to gain an unfair advantage, giving or receiving excessive entertainment or gifts, embezzlement such as the improper receipt of kickbacks or rebates, unfair competition such as bid rigging or collusion, extortion, fraud, money laundering, etc.
Specifically, we have established the "Kirin Group Anti-Corruption Policy," "Kirin Group Anti-Bribery Rules," etc., based on deliberations by the Group Risk and Compliance Committee, which is formed by Kirin Holdings' Directors of the Board and Senior Executive Officers. These policies and rules shall apply not only to all executives and employees working for the Group, but also to all business partners, agents, etc., and we require that they shall comply with them.
The policies and rules are made available to the entire Group through internal notification materials and the intranet, etc., so that they can be accessed at any time. We provide copies of policies and regulations to new employees in Japan. We also conduct periodic educational and training programs for executives, employees, and other related parties, including business partners and agents.
In addition, we require Group companies operating in countries with high bribery risk to conduct periodic anti-corruption training for employees and annual self-assessments of risk, and Kirin Holdings confirms the details of these assessments, also we use outside attorneys and other resources to investigate the status of anti-bribery efforts. If we discover any conduct that constitutes corrupt practices, we will report it through the hotline.
Initiatives to Prevent Misconduct in Research Activities
To prevent misconduct in the research activities of each company involved in Kirin Holdings Company, Limited, we have established and operate a consultation and whistle-blowing system, put in place internal regulations, and conduct training in accordance with the Kirin Group’s Compliance Guidelines.
- General manager (person with the authority to oversee overall efforts to improve research ethics and prevent misconduct, etc.): Head of Kirin Holdings Company, Limited Research and Development Division
- Divisional managers (personnel responsible for improving research ethics and preventing misconduct in relevant divisions and departments): Head of Kirin Holdings Company, Limited Research and Development Division and the heads of research and development divisions of regional companies (for Mercian, the head of each technological division and department).
- Research ethics education managers (personnel with substantial authority in regard to research ethics education): Personnel appointed by the divisional managers.
Response to violations
The Group shall refuse to continue transactions by its business partners or agents whenever it becomes aware of any violation of compliance, including anti-corruption violations. In addition, executives and employees will be punished strictly and promptly in accordance with the internal rules and employment rules of each Group company.
In the event of a violation, compliance officers of each Group company and the secretariat of the Group Risk and Compliance Committee take the lead in proactively investigating the cause of the matter in question and formulating measures to prevent recurrence. The PDCA cycle is firmly established through periodic monitoring and reporting to the Group Risk and Compliance Committee on the status of the response.In addition, procedures for the establishment of a task force in the event of an emergency have also been established.