Main Activities
Establishment of Internal Regulations
We established the Teijin Group Anti-Corruption Policy under which we lay out procedures and establish the framework for preventing corruption. In addition, we have formulated conduct guidelines for preventing corruption and work to ensure that our corporate officers and employees rigorously adhere to these guidelines.
In principle, our guidelines prohibit entertaining or providing gifts to public officials and other members of public institutions. In the event that there are logical grounds for providing benefits to or incurring expenses for public officials, prior approval must be obtained by responsible personnel in our organization. In addition, when making a donation or offering aid, employees are required to make use of a checklist to confirm that such donation or aid does not constitute the bribery of public officials.
In addition, we perform due diligence to confirm the eligibility of potential business partners from the perspective of preventing corruption conducted by external partners. We also conduct appropriate due diligence of target companies when conducting corporate acquisitions to confirm that there is no past or current corruption. We require suppliers to comply with our CSR Procurement Guidelines including the prohibition of bribery.
Management of Corruption Risks at Our Business Partners
We conduct due diligence to confirm the validity of transactions in order to prevent corruption occurring in transactions with business partners.
In particular, when starting or continuing the appointment of a sales agent, we confirm corruption risks based on a checklist (confirming presence/absence of items such as special interests with public officials, past corruption, capabilities to perform duties, and claims for unaccounted-for expenditures) and require that the sales agent sign an anti-corruption oath.
We clearly communicate our CSR Procurement Guidelines, including the prohibition of bribery, to our suppliers and request their thorough adherence to these guidelines. We also enact measures toward transactions with suppliers that have contributed to corrupt behavior, including the suspension of transactions with such suppliers for a set period of time.
Also, when conducting a corporate acquisition or merger, we conduct due diligence of the partner company related to corruption risks.
FY2022 Activity Results
Risk assessment
From FY2019 to FY2022, we conducted assessments via an external law firm targeting each business and site of each Teijin Group company in order to clarify the exposure of the risk of corruption throughout the entire Group. In FY2022, the assessment targeted six overseas Group companies. The results of these assessments to date have not identified any business or site with significant corruption risks.
For businesses that deal with public institutions including governmental organizations, however, it was recommended that development of management systems and appropriate regular trainings be conducted, preferably in accordance with Teijin Limited fundamental policies, taking into consideration local characteristics at the site of business.
Education
From the second half of FY2021 to the beginning of FY2022, we implemented anti-corruption e-learning for about 2,300 officers and employees responsible for operations such as sales, procurement, and collaboration with other companies, at each business and site of each Teijin Group company.
Status of violations of laws and regulations relating to corruption
In FY2022, it was discovered that two employees had engaged in conduct that contributed to corruption. These employees were dealt with in accordance with internal regulations at their respective Group companies.
In addition to reviewing work procedures and further establishing anti-corruption policies and internal regulations, we will provide anti-corruption educational activities to officers and employees at said companies to prevent a reoccurrence of such conduct.
Future Issues
We periodically conduct internal audits and risk assessment surveys and assess and review the PDCA cycle for the prevention of corruption.
In addition, we are committed to regular implementation of relevant education and training regarding anti-corruption within the Group, as well as to promoting extensive use of the internal reporting system and consultation hotlines when employees face risks such as bribery. We are working to gradually develop a reporting system for outside business suppliers.
Status of the Provision of Capital
In principle, the Teijin Group does not make political donations. In the case of expenditures necessary for the conduct of business, however, donations may be made within the scope of relevant regulations and in accordance with the Regulations for Teijin Group Responsibilities and Authorities.
Also, within the Teijin Group, Teijin Pharma Limited, Group companies that engage in the pharmaceutical, medical devices, and regenerative medicine businesses have established policies relating to transparency in relationships with medical institutions and disclose the status of the provision of funds to such organizations in accordance with these policies.