Compliance
Toward Fair and Transparent Corporate Activities

The DIC Group Code of Business Conduct

The DIC Group Code of Business Conduct (amended in October 2024) not only mandates compliance with national laws and international rules but also presents 10 principles essential to the professional conduct of DIC Group employees.

The Group held presentations for all existing Group employees when the code was originally established, while new employees receive training at point of hire. The goal of such training is to ensure employees worldwide share values cherished by the Group and approach their work with a sense of responsibility and a commitment to doing the right thing.

Initiatives to Promote Compliance

The DIC Group promotes compliance through the following initiatives:

• Legal training that emphasizes improving compliance awareness is provided for employees at point of hire, when promoted and before transfer overseas. In addition, to promote awareness of the DIC Group Code of Business Conduct, e-learning and theme-specific presentations related to the code, as well as to compliance, is provided in Japan, at DIC Asia Pacific Pte Ltd, at DIC (China) Co., Ltd., and in the Americas and Europe.
• Compliance officers are appointed at all regional headquarters—DIC (Japan), Sun Chemical Corporation (the Americas, Europe, the Middle East and Africa), DIC (China) (PRC) and DIC Asia Pacific (Asia and Oceania)—to spearhead global compliance efforts.

The DIC Group vows that it will not violate the principles of the DIC Group Code of Business Conduct, even if such a violation would appear to profit the Group. As a corporate citizen, the Group also pledges to respect social norms and act in a sound and socially acceptable manner. In fiscal year 2024, there were no serious violations of compliance laws.

Establishing and Operating a Whistle-Blowing System

The DIC Group has established a compliance whistle-blowing system independent from channels for communication used in the conduct of business. (This system also encompasses external hotlines that can accommodate more than 160 languages.) The Group encourages use of this system to promptly address compliance-related issues and suspected compliance violations. The Group has also devised strict rules under this system to protect whistle-blowers from retaliation and works to ensure the system functions in a proper manner.

When a report is received, the DIC Group responds swiftly and appropriately, giving due consideration to pertinent laws while also incorporating internal and external opinions, to identify and correct violations and where necessary to take disciplinary action. Details of reports and steps taken in response are reported to the Board of Directors. The Group will continue to use its whistle-blowing system to ensure the prompt discovery and correction of misconduct.

In fiscal year 2024, 45 reports were received on compliance issues and labor-related matters such as power harassment and discrimination, but none were judged to be serious. The substance of these reports was conveyed to the Board of Directors.

Preventing Violations of Antitrust and Anti-Corruption Laws

The DIC Group established a basic policy for compliance with antitrust legislation in February 2006 and has since made efforts Groupwide to ensure fair business practices. Strict rules for compliance with antitrust legislation and the prohibition of involvement in corruption are contained in the DIC Group Code of Business Conduct. These are also among the themes addressed in e-learning held annually to bolster employee understanding and advance awareness.

Promoting Compliance with Legislation Regarding the Timely Payment of Subcontractors

With the aim of enhancing understanding of the importance of appropriate and fair transactions with subcontractors, the Legal Department held presentations on legislation regarding the timely payment of subcontractors, incorporating case studies, for the purchasing departments of domestic DIC Group companies, and offered e-learning, principally for employees in charge of subcontractors. In addition, DIC has prepared the Manual for Internal Auditing of the DIC Group’s Compliance with Japan’s Act Against Delay in Payment of Subcontract Proceeds, Etc., to Subcontractors and created a framework for conducting audits in a more efficient manner. The Group also encourages employees in related positions to participate in programs sponsored by external organizations, including a workshop promoting adherence to the Act sponsored by the Japan Fair Trade Commission and the Small and Medium Enterprise Agency.