Basic Concept of Compliance
Sumitomo Electric believes that complying with laws and regulations and maintaining corporate ethics comprise the backbone of its management; these matters are its social duties as a corporation, and form the absolute basis for the Company's continued existence and development. In recognition of this understanding, Sumitomo Electric has developed the compliance system. Despite our efforts in this regard, in February 2003 Sumitomo Electric received notice from the Japan Fair Trade Commission advising us to end a practice that violated the Antimonopoly Act. This has provided us with an opportunity to thoroughly review our activities and redouble our ceaseless efforts to further strengthen our compliance. We will continue our efforts to disseminate awareness of compliance and enhance the system across the Group.
Compliance Committee
Sumitomo Electric 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 Employee Compliance Manual 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 department and division. For Group companies in Japan and overseas, Sumitomo Electric also provides guidance and support for the establishment of their own compliance system based on the outcome of the Company's compliance initiatives.
Initiatives to Disseminate Compliance Awareness
Panel of the Sumitomo Spirit
To check compliance risks, ensure implementation of preventive measures 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 compliance training seminars.
The Sumitomo Spirit, which forms the basis of the SEI Group's compliance system, as well as our philosophies and code of conduct mentioned in the SEI Group Corporate Principles and the SEI 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.
* Please see the following page for the Sumitomo Spirit, SEI Group Corporate Principles, and SEI Group Charter of Corporate Behavior.
Corporate Philosophy
Dissemination among Group Companies Overseas
With the globalization of our business, we are making more efforts to develop the compliance system in Group companies overseas. The Business Code of Conduct has been introduced to overseas consolidated subsidiaries, which complies with the laws and regulations of the respective regions. We also provide compliance training seminars for local managers, which consist of two parts: (1) the importance of compliance and our Group's initiatives and (2) local laws and regulations and actual cases of troubles (lecturer: local attorney).
Global Manager Development Program
In the Global Manager Development Program, a training program for managers invited from our overseas affiliated companies as part of SEI University activities, we are strive to disseminate awareness of compliance and to create a sense of unity among the SEI Group through lectures on Sumitomo’s history and business spirit, VISION2012 and compliance as well as group discussions on practical subjects.
Speak-Up System
We have established 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. In addition to the Company's compliance staff, a law firm has been appointed as an external contact in the Speak-Up System. To address issues reported through this System, the Compliance Committee swiftly conducts investigation and takes necessary action. In March 2006, Sumitomo Electric instructed Group companies in Japan to establish their own in-house consultation contacts. At the same time, Sumitomo Electric decided to position outside contacts in its Speak-Up System, as outside contacts for compliance consultation for the entire SEI Group. We are working to disseminate the system to employees through monthly in-house magazines and other means to enable them to recognize the system and use it promptly when needed.
