Compliance

Compliance

The Nichirei Group conducts various activities intended to maintain high ethical standards and to comply with the laws and social norms of each country in which it operates. To ensure that all employees comply with laws and Nichirei's internal regulations, and act in keeping with corporate ethics, Nichirei formulated and distributed a code of conduct and examples of how the code is applied and clarifying the guiding principles by giving specific examples. Employees around the world are also provided with the Group's code of ethics, which has been translated in eight languages including English, French, Chinese, and Thai. We also conduct compliance training sessions for regular employees, in order that they might better understand the principles and structure of compliance management.

Code of Conduct

Nichirei formulated its code of conduct in April 1999, with content focused mainly on Japan. Much of the content became irrelevant as Nichirei expanded globally so, in April 2014, we created an international version of the code of conduct, designed to strengthen corporate governance for the entire Group, and ensure legal compliance and ethical business activities. The main points of the revision include the addition of “respect for human rights” as part of the first principle, derived in part from the Ten Principles of the UN Global Compact. We also incorporated principles we judged to be important from the standpoint of global compliance, including the prohibition of insider trading, and involvement in, or dealings with, antisocial forces.

Nichirei Group Code of Conduct (Table of Contents, revised April 2014)

  • 1. Compliance with laws and regulations concerning respect for human rights and labor
  • 2. Environmental protection
  • 3. Compliance with laws and regulations, and internal regulations
  • 4. Management and preservation of the Company's property
  • 5. Prohibition of personal use of Company property
  • 6. Prohibition of insider trading
  • 7. Ensuring the reliability of financial information
  • 8. Management and use of information
  • 9. Prohibition of personal acts conflicting with the Company's interests
  • 10. Prohibition of unfair benefits given to, or received from, public officers or business partners
  • 11. Prohibition of involvement in, or trade with, antisocial forces
  • 12. Compliance with, reporting of, and consultations concerning, code of conduct

Educating Employees about the Code of Conduct to Ensure Compliance

The Group seeks to continue commanding trust, based on the high ethical standards of its board members and employees. Following the April 2014 revision of our code of conduct, we included it and the Group management principles in the employee handbook.

In addition, a guidebook on the use of social media has been distributed to all employees and, on the Group's intranet, we publish a monthly series of slideshow-style materials designed to help employees understand case studies related to the code of conduct.

In fiscal 2016, seminars were organized for section managers from all relevant departments in order to raise their awareness of the need for compliance. A total of 104 people participated in four seminars held in January and February 2017. The seminars were designed to reaffirm the significance of, and need for, compliance, as well as to review the Group's compliance-related policies. During training, participants examined their role as group leaders in ensuring and promoting compliance, including the prevention of harassment.

In addition, the Nichirei Group has been offering e-learning sessions to educate and train employees, based on its in-house educational rules. A total of 12 sessions were held in fiscal 2016 covering a variety of topics, including compliance with competition-related laws, prevention of bribery and corruption, and prevention of harassment.

The Nichirei Group is committed to continue providing compliance training.

E-learning training sessions conducted in fiscal 2016
  E-learning Topic Eligible Participants Actual Participants Participation Rate
1 Food quality, hygiene, and safety assurance (part 1) 5,243 4,729 90.2%
2 Internal controls (part 1) 5,195 5,056 97.3%
3 Environment (part 1) 5,190 5,071 97.7%
4 Intellectual property 5,233 4,874 93.1%
5 Internal compliance report 5,234 5,009 95.7%
6 Social security and taxation number system 5,203 4,877 93.7%
7 Competition law; bribery and corruption prevention 5,183 4,922 95.0%
8 Internal controls (part 2) 5,194 5,075 97.7%
9 Harassment 5,216 5,029 96.4%
10 Food quality, hygiene, safety assurance (part 2) 5,206 5,045 96.9%
11 Environment (part 2) 5,183 5,029 97.0%
12 Information security 5,184 4,983 96.1%

Internal Whistleblower Hotline and Consultation Service

In October 2003, Nichirei introduced an internal reporting and consultation hotline. This allows employees to report, or seek advice on, actions that violate laws or company regulations, or that are ethically questionable.

In FY2015, Nichirei updated its whistleblower hotline in response to the requirements of Japan's new Corporate Governance Code. This requires that internal whistleblower systems be independent from a company's management. To ensure that all employees are aware of the new hotline, Nichirei created and distributed promotional posters for its workplaces and reminder cards for employees.

Over the past three years, an increasing number of reported cases have involved workplace disputes and harassment.

In accordance with company policy, all reports received are relayed to top management by the administration office, which also conducts an investigation to confirm the facts, implements corrective measures, and provides feedback to the person who made the report (when not reported anonymously).

Anonymity is preserved to protect the identity of the person reporting, while the process is carefully managed to ensure there is no retaliation against, or adverse treatment of, those who are the subject of complaints.

Cases by Year
FY2012 3
FY2013 8
FY2014 9
FY2015 13
FY2016 20
Cases by Issue (over Five Years)
Workplace disputes 9
Harassment 24
Compliance-related breaches 5
Mistreatment 7
Other consultations 8

Group Management Audits

Nichirei conducts audits in accordance with internal Group auditing regulations, in order to ensure that its risk management structure-encompassing all Group companies-remains in place, and to keep growth healthy and sustainable.

To raise compliance consciousness throughout the Group, we provide all Group companies and business offices with a management audit checklist, that specifies items to be reviewed, suggests voluntary checks, and assesses the effectiveness of the internal control system.

Intellectual Property Rights

The Group complies with laws and regulations regarding intellectual property, and respects the intellectual property rights of others. From this foundation, we pursue originality, and conduct intellectual property-related activities to provide better products and services.

For example, we take action to acquire rights to those products of our R&D program from which we can derive appropriate added value through patent rights. Further, to protect the brand that guarantees the quality of our products, we diligently maintain the trademark rights that indicate our products and services.

Nichirei also provides employees with learning opportunities, to enhance their knowledge and reinforce the appropriate measures vis-a-vis intellectual property rights. We conduct e-learning for all employees and courses open to the public, to provide opportunities for everyone to have the necessary facts regarding intellectual property. Employees who require further knowledge or have an interest can schedule individual follow-up sessions with intellectual property specialists, or obtain a referral to attend a particular study session, all of which helps foster sensitivity to intellectual property rights.

Information Security and Protection of Personal Information

Based on the advice of the Group Risk Management Committee, the Group has established a basic policy regarding information security measures for all Group companies and employees to observe. It provides the level of information management currently demanded by society, as well as effectiveness and efficiency in the operations of Group companies.

We have established a plan-do-check-action (PDCA) management cycle, to ensure 1) personal and organizational security; 2) physical security; and 3) technical security. In addition, to clarify the system of responsibility for the protection of personal information, each company has designated a chief privacy officer (CPO) and manager responsible for handling personal information.

Industry Organizations

The Group is involved in the activities of several industry organizations, including the Japan Frozen Food Association, and the Japan Association of Refrigerated Warehouses. We are helping to improve and resolve issues facing society in a number of ways, including by providing advice and making proposals.