Compliance
The Nippon Soda Group ensures corporate activities are undertaken in compliance with laws and ordinances and corporate ethics by making all employees aware of the Nippon Soda Group Code of Conduct. Our efforts to ensure business management that emphasizes regulatory compliance include the establishment of the Compliance Committee and proper implementation of the internal reporting system. Through these efforts, we enhance the internal control system and continue to be a company trusted by society.
The Nippon Soda Group Code of Conduct
| 1. Compliance with laws/ordinances and corporate ethics | (1) Fair actions (2) Compliance with corporate ethics (3) Prompt corrective action and strict disciplinary action in response to the violation of a law/ordinance |
|---|---|
| 2. Relationship with society | (1) Contribution to society (2) Compliance with various kinds of business laws (3) Regulation of donations and political fund contribution (4) Severance of relations with anti-social forces (5) Environmental conservation/protection (6) Compliance with laws/ordinances related to security trade control and export/ import |
| 3. Relationship with customers, business partners and competitors | (1) Product safety (2) Compliance with the Anti-trust law and competition law (3) Appropriate transactions with suppliers and complying with the subcontracting law (4) Prevention of unfair competition (5) Business entertainment and gifts (6) Prohibition of presenting bribery to foreign public officials (7) Appropriate publicity/advertising |
| 4. Relationship with shareholders and investors | (1) Disclosure of managerial information (2) Prohibition of insider trading |
| 5. Relationship with individuals | (1) Respect for human rights and prohibition of discrimination (2) Harassment (3) Protection of privacy (4) Safety and health in workplace (5) Compliance with labor relations laws |
| 6. Relationship with the Company and corporate assets | (1) Compliance with work regulations (2) Appropriate accounting (3) Conflicts of interest (4) Prohibition of political and religious activities (5) Management of trade secrets (6) Appropriate use of corporate assets (7) Appropriate use of information systems (8) Protection of intellectual property rights |
| 7. Supplementary provisions | (1) The scope of application of this Code of Conduct (2) Revision and abolition of this Code of Conduct (3) Violation of this code of conduct / consultation hotline (4) Penalty |
Compliance Promotion System
Nippon Soda has a Compliance Committee, which is chaired by the director in charge of compliance with legal departments serving as the secretariat, to ensure corporate activities in compliance with laws and ordinances and corporate ethics throughout the Group. Furthermore, to ensure thorough implementation of the Nippon Soda Group Code of Conduct, we have appointed a staff member in charge of compliance at each department, worksite and subsidiary.
The Nippon Soda Group has established a consultation desk, whereby an employee of the Group who has committed an infraction or becomes aware of an infraction by another employee, can consult directly with the Compliance Committee Secretariat, an outside attorney or an Audit and Supervisory Committee member.
Compliance Promotion and Education
We have formulated the Nippon Soda Group Code of Conduct, which specifies matters to be observed by the Nippon Soda Group in order to carry out sound corporate activities. In addition to introducing and enhancing awareness of this Code of Conduct throughout the Company, as well as at our subsidiaries both in Japan and overseas, we provide ongoing training to ensure thorough compliance with laws and ordinances. We conduct legal education and training related to our operations once a year or more, and in FY 2023, we conducted a total of 12 major compliance training sessions for the Company and its subsidiaries. Elsewhere, we also have e-learning programs aimed at enhancing awareness of the Code of Conduct among all Company and subsidiary executives and employees, and the current completion rate stands at 98%. Moreover, for staff members in charge of compliance at the Company and its subsidiaries, we also host seminars that look at how to respond to cases through the internal reporting system. In addition, we conduct an annual compliance survey of all employees to determine their understanding of the Code of Conduct.
Education on laws and ordinances related to chemical and product safety
Nippon Soda provides educational and explanatory sessions on laws and ordinances related to the management of chemical substances on a regular basis.
| No. | Programs and contents | Site and date | Number of participants |
|---|---|---|---|
| 1 | Pharmaceuticals education for new/transferred employees (Content: Fundamental pharmaceuticals education, Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices violations, and recurrence prevention measures) | Head Office June 30, 2022 |
3 |
| 2 | Education to prevent recurrence of violations of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. | Head Office, Nihongi Plant, Takaoka Plant, Mizushima Plant, Chiba Plant, Odawara Research Center, Chiba Research Center June 27, 28, 29, 2023 (includes viewing of recorded materials) |
388 |
| 3 | Pharmaceuticals education (Content: Responsibilities, management system, changes to certificate of approval for manufacture and sale, revisions to internal standards, activity plans and achievements, safety management information, Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices violations, and recurrence prevention measures, etc.) |
Head Office, Nihongi Plant, Osaka Branch Office February 27, 2023 |
8 |
| 4 |
Briefing on revisions to laws and ordinances (Content: Revisions to the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., the Industrial Health and Safety Act, the Poisonous and Deleterious Substances Control Act, the Act on Confirmation, etc. of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof, the Fire Service Act, and the Food Sanitation Act, revisions to JIS for SDS and labels, and revisions to overseas laws, etc.) |
Head Office, Osaka Branch Office, Nihongi Plant, Takaoka Plant, Mizushima Plant, Chiba Plant, Odawara Research Center, Chiba Research Center January 16, March 2, 2023 (includes viewing of recorded materials) |
208 |
| 5 | Briefing on chemical substance control system’s response to the revised Act on Confirmation, etc. of Release Amounts of Specific Chemical Substances in the Environment and Promotion of Improvements to the Management Thereof | Head Office, Nihongi Plant, Takaoka Plant, Mizushima Plant, Chiba Plant, Odawara Research Center, Chiba Research Center October 20, 24, November 1, 2022 |
70 |
| 6 | Seminar on chemical substance control system use | Head Office, Nihongi Plant, Takaoka Plant, Mizushima Plant, Chiba Plant, Odawara Research Center, Chiba Research Center March 10, 17, 2023 |
75 |
Significant fines for violation of laws and regulations related to the provision or use of products and services
No relevant events occurred.
Political contributions
As outlined in the Nippon Soda Group Code of Conduct, political contributions are only made in compliance with relevant laws and ordinances and using appropriate methods and procedures. Nippon Soda’s political contributions in FY 2023 were ¥22,727.
Internal reports related to compliance (FY 2023)
The internal reporting hotline received two reports of violations of the Nippon Soda Group Code of Conduct. (Scope: all Nippon Soda and subsidiary executives and employees)
Reports related to legal violations
- 1.TEAI-1000 was in violation of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.
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(1)Overview
Although we submitted a notification and received a decision regarding a new chemical substance as per the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., (Reference Number in the Gazetted List: 6-3577), the product contained more than 1% of a substance with a molecular weight of less than 1,000, and the substance was found to deviate from the scope specified by 6-3577. - (2)Cause
- (1)In submitting notification regarding a new chemical substance as per the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., the test substance used to acquire test data differed from the actual industrial product, leading to the above violation. We lacked the proper system to check the eligibility of the test substance.
- (2)Due to insufficient understanding and recognition in certain procedures of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., among those concerned, even when (1) came to the fore, we could not quickly implement the appropriate countermeasures.
- (3)Recurrence prevention measures
- (1)In addition to revising our internal regulations and reviewing methods for the confirmation/submission of information on existing and new chemical substances, we have created a system whereby the department in charge of submissions checks and keeps a record of the eligibility of the test substance used to acquire test data, in turn reinforcing accountability and traceability.
- (2)We revised and clarified internal regulations on our response to emergency situations, such as violations of the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. We also provided education to those concerned on the revisions we made to our internal regulations and on the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. Moreover, we will also offer regular compliance education to ensure thorough legal compliance.
- 2.Nisso Melsan ST was in violation of the Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices
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(1)Overview
Of the dosage and administration information displayed on the product packaging film, the dosage information was incorrect. The packaging should have stated “Dissolve one tablet in between 1.4–6.1 m3 of septic tank effluent,” but instead incorrectly stated “Dissolve one tablet in between 0.8–3.6 m3 of septic tank effluent.” -
(2)Cause
When we previously responded to the shift to the Globally Harmonized System of Classification and Labelling of Chemicals for the information displayed on our packaging film, our first response was to change the design of one of our separate brands. With this violation, we suspect that in addition to the design, we also incorrectly used the dosage information from this separate brand. Due to insufficient checking and self-inspection methods/items at the time of change, we could not prevent the mislabeling of dosage or quickly discover our fault. -
(3)Recurrence prevention measures
We created a system whereby the impacts of any changes on quality, sales, and manufacturing approval documents are assessed and recorded. We also revised our internal regulations and reinforced our manufacturing/quality management for pharmaceuticals, such as by adding checks of dosage and administration into self-inspections.
