Compliance
Basic Concept of Compliance
Sumitomo Electric believes that complying with laws and regulations and maintaining corporate ethics comprise the backbone of its management and form the absolute basis for the Company's continued existence and development.
With a proud history spanning over 120 years, the Sumitomo Electric Group has a long tradition of conducting business in accordance with the principles of the Sumitomo Spirit. We strive for excellence in our work, and we strive for integrity in our business conduct. We operate not only within the letter and spirit of laws and regulations, but also in accordance with the highest ethical standards.
Code of Conduct
The Code is a statement of our shared values and the standards of conduct that are expected of each of us. It describes the fundamental principles and key policies that govern how we conduct business. The Code applies to all Company employees, officers, and directors, at every level. We distribute this Code of Conduct to Sumitomo Electric Group companies worldwide.
Supplier Code of Conduct
Sumitomo Electric Group seeks to do business with suppliers that share our commitment to integrity and to conducting business in compliance with the law.
The Supplier Code of Conduct is a statement of the values and the standards of conduct that we expect of each supplier, subcontractor, agent, consultant, or distributor.
It is applicable to all suppliers to Sumitomo Electric Group companies worldwide.
Compliance Promotion System
Compliance Committee
The Sumitomo Electric Group has established the Compliance Committee, chaired by the President, as an organization that promotes measures necessary to develop and further strengthen the compliance system. The Committee engages in various activities, including preparing and distributing the Sumitomo Electric Group Code of Conduct and organizing compliance training seminars. In addition, the Committee identifies and analyzes Group-wide compliance risks, disseminates preventive measures Group-wide, and monitors the compliance activities implemented by each division and subsidiary.
Speak-Up System
We have put in place the Speak-Up System, which enables employees to directly report and consult on potential compliance-related issues, so as to identify and resolve such issues by ourselves at an early stage. Such reporting and consultation can be made internally through the Company's compliance contact or through a third party appointed as an external contact in the Speak-Up System. While Sumitomo Electric Group companies are encouraged to establish their own in-house hotline contacts, the above-mentioned external contact is also made available for use by Sumitomo Electric Group companies worldwide. The hotlines are available not only to our employees but also to families and business partners outside the Company. For more information on hotline, please see below:
Efforts to Raise Awareness of Compliance
Compliance Training
To check compliance risks, ensure implementation of preventive measures and develop and enhance awareness of compliance, the Compliance Committee organizes regular training seminars for all officers and administrative members every year. New employees and newly promoted personnel are also provided with training seminars.
The Sumitomo Spirit, which forms the basis of the Sumitomo Electric Group's compliance system, as well as our philosophies and code of conduct mentioned in the Sumitomo Electric Group Corporate Principles and the Sumitomo Electric Group Charter of Corporate Behavior are also disseminated by, for example, holding a variety of training programs and citing comments made and actions taken by top management.
*Click here on the Sumitomo Spirit, the Sumitomo Electric Group Corporate Principles, and the Sumitomo Electric Group Charter of Corporate Behavior.
Awareness of Compliance among Group Companies
We are also committed to the development of the compliance system among worldwide group companies in line with the globalization of our businesses. Sumitomo Electric provides compliance training seminars for all management levels regardless of their location.
In addition, as part of SEI University activities, we organize the Global Leadership Development Program to develop awareness of compliance and create a sense of unity among the Sumitomo Electric Group with lectures on Sumitomo’s history and the Sumitomo Spirit , our group’s business visions and compliance, and through group discussions on practical subjects.
Competition Law Compliance
System
To eliminate competition law violations including cartel and collusion by the Group companies, we adopted Global Antitrust and Competition Policy in February 2020 and have obliged directors, officers and employees to comply with it. In addition, under the supervision of the Compliance Committee, the Compliance & Risk Management Office (established in the Corporate Staff Group), together with the sub-organizations dedicated to competition law compliance and the Compliance Liaison of each of the Business/Sales Units, forms a system to monitor the operation of, and compliance with, the Competition Law Compliance Regulations which includes rules to restrict contact with competitors. In this way, all the directors, officers and employees are firmly engaged in competition law compliance.
Anti-bribery
Compliance
System
Sumitomo Electric introduced an anti-bribery program in April 2013 to enhance its anti-bribery compliance system on a global scale. This program has established rules on bribery-related issues, including ban of bribery, as well as ex ante approval and ex post report on gifts, donations and offering entertainment, in the Bribery Prevention Compliance Policy in response to the recent tightening of regulations on bribery of domestic and foreign public officers in the US, Europe and emerging markets. Compliance Liaison is appointed in each unit to build a system to apply the rules.
Privacy Protection
Our Group complies with rules and regulations regarding personal data protection and handles such information accordingly, both as regards our business associates and our own employees. In recent years, the EU passed the General Data Protection Regulation (GDPR) and other countries have tightened their regulations to protect personal data, and we are taking measures to comply with these new regulations.
Tax Policy
Based on the Sumitomo Spirit, the Sumitomo Electric Group Corporate Principle and Code of Conduct, we shall establish Sumitomo Electric Group tax policy.
Sumitomo Electric Group is committed to conduct its business affairs in a fair and responsible manner, and we shall contribute to the development of the society through proper tax payment.
