Targets and Achievements of Major Approaches
|Objective / Task||FY 2011Goals||FY 2011 Results||Evaluation||FY 2012 Goals|
|Raise awareness of compliance||・Create and distribute a digest of the DIC WAY to promote understanding of the code of conduct||・Finished preparing Japanese and English materials; Chinese materials not yet complete
・Utilized e-learning materials while promoting further ntegration of the code of conduct
|★★||Revise the contents of the 2008 edition of the DIC WAY Code of Business Conduct and finalize the contents of the 2013 edition|
|Conduct business fairly||・Create e-learning resources for the Subcontract Act and ensure thorough compliance||・Completed a basic draft for e-learning materials||★★||Complete easy-to-understand materials and provide e-learning education for employees involved in subcontracting deals|
Basic Concept of Compliance
Compliance in the DIC Group is to not only comply with laws but also respond to and meet social norms and requirements by stakeholders, such as customers, communities, and society. We consider that the compliance and adherence to the “DIC Way Code of Business Conduct”, which is the unified set of guidelines to be followed by DIC Group employees, is the basis of compliance. We pursue actions that comply with this Code in the business activities in order to achieve sustainable growth of fair and transparent businesses of the DIC Group.
Program to Promote Compliance
The “DIC Way Code of Business Conduct” embodies the principles of action based not only on compliance with laws in every country and international rules but also on social norms, expectations, and requirements of each ountry/region worldwide in order for the DIC Group to not only fulfill its social responsibilities as a corporate citizen but also accurately respond to the values required by stakeholders worldwide, such as customers and societies, etc., and achieve sustainable growth of the group’s businesses. DIC Group employees are required to base their decision-making for all of their duties and work-related matters on this Code. We promote the establishment of the “DIC Way Code of Business Conduct” not only by holding explanatory seminars for DIC Group employees but also through e-learning. In addition, we also hold legal seminars for employees who are newly employed, promoted and transferred overseas in order to enhance their awareness of compliance. The DIC Group will continue to never violate the principles setforth in this Code, even if such violation would appear to be profitable for the DIC Group. We also respect fair social norms and act with social wisdom as a corporate citizen.
System to maintain compliance
The DIC Group utilizes the whistle-blowing system. In case of issues or questions regarding compliance, one can directly report the matter to the president, auditors, and external attorneys, etc. In case of such reports, we appropriately respond to such reports according to the law while incorporating internal and external opinions with the aim of finding and correcting wrongful conducts, etc. in an early stage. The DIC Group is operating globally and has established a global compliance promotion system led by DIC Corporation（Japan）, Sun Chemical Corporation（Europe and U.S.A.）, DIC（China） Co., Ltd.（China）, and DIC Asia Pacific Pte Ltd.（Asia/Oceania）as the core members.
Compliance guidelines by Sun Chemical
The Sun Chemical Group has established its own “code of business conduct and guidelines” in addition to the “DIC Way Code of Business Conduct” and thoroughly complies with these rules. All employees are required to undergo the e-learning courses and sign a letter of acknowledgement. By doing so, the group commits to enhancing and maintaining the awareness for compliance. In addition, the group also has established an ethical hotline to enable relevant parties within and outside of the Sun Chemical Group to enhance the fairness and transparency of their businesses by thoroughly executing the reports sent via this hotline.
Sun Chemical Corporation
Mr. Eric Finkelman
Vice President and General Counsel