In the DUNLOP Group, we believe that “legal compliance and the upholding of corporate ethics form the cornerstone of a company’s survival and are crucial to long-term corporate vitality and competitiveness.”
The Group formulated the Regulations on Corporate Ethics Activities and the DUNLOP Group Corporate Code of Conduct in 2003. These principles are continually enforced, informing our efforts to develop a compliance structure for the entire Group and foster compliance awareness among employees. In addition, in 2004, we established a “Corporate Ethics Helpline” offering an in-house point of contact and have commissioned an external lawyer to serve as an external contact. Furthermore, we provide all employees with a compliance card featuring a message to instill compliance awareness and the abovementioned helpline contact information to facilitate reporting. In this way, we ensure that every employee knows about the compliance reporting line, which operates outside the regular reporting lines within the job hierarchy. We have thus developed a structure capable of ensuring the early detection of misconduct.
In February 2004, the Group established the Corporate Ethics Helpline, an internal reporting line designed to accommodate requests for consultation regarding various issues associated with corporate ethics, including harassment, monopolistic practices, corruption, and other misconduct. The Corporate Ethics Helpline consists of internal and external consultation contacts, which are available not only to all officers and employees of the Group, but also to external parties such as suppliers who do business with the Group. Consultations and reports to the Corporate Ethics Helpline are kept strictly confidential, and any unfavorable treatment from such consultations is prohibited. In addition, the usage status of the Corporate Ethics Helpline is reported to the Corporate Ethics Committee once every quarter and to the Board of Directors regularly.
In 2003, we established “DUNLOP Group Corporate Code of Conduct,”which has been translated to eight languages including Japanese and known to all officers and employees. It provides clear guidelines regarding the basic stance they should take and the mindset they should adopt in the course of their business activities from the aspect of legal and regulatory compliance. Also, we provide all employees with a compliance card featuring a message designed to instill compliance awareness as well the contact information of the Corporate Ethics Helpline. In this way, we ensure that every employee knows about the compliance reporting line, which operates outside the regular reporting lines within the job hierarchy, and that any misconduct is detected promptly.
The DUNLOP Group continues its activities to ensure thorough compliance, extending its scope to include not only its own employees but also business partners,
contractors, agents, and third parties playing an intermediary role, including joint ventures.
The Group has established the “DUNLOP Group Code of Conduct” to ensure thorough compliance, including the prevention of corrupt practices and bribery.
We distribute leaflets to all employees and take other measures to ensure awareness of its contents.
Furthermore, for business partners, we provide procurement guidelines incorporating prohibitions against corruption, bribery, and graft at the time of contract signing. We also include anti-corruption clauses in contracts, advancing efforts to ensure compliance throughout the entire supply chain.
We also conduct compliance training sessions for third parties, including intermediaries, to raise awareness about corruption prevention.
Furthermore, in contracts with all business partners, including intermediaries, we explicitly state compliance with our Group's anti-corruption policy, which includes a comprehensive prohibition on bribery and corruption.
When conducting M&A (such as acquiring businesses or shares from other entities) or engaging agents for business activities, we perform appropriate due diligence tailored to each region and country to verify that the counterparties and agents maintain robust compliance.
Furthermore, we annually assess the sustainability initiatives of our suppliers through EcoVadis, an international corporate sustainability rating provider. This assessment broadly covers environmental, social, and governance aspects, and we also monitor anti-corruption and bribery prevention efforts through the evaluation results.
The Corporate Code of Conduct is a set of specific guidelines based on the Group’s corporate philosophy framework, “Our Philosophy,” which sets forth the basic stances and approaches of all officers and employees of the Group in conducting business activities from the perspective of legal compliance. We believe that the thorough implementation of the Corporate Code of Conduct is essential for the stable continuation of our business. We will continue to promote awareness of the Corporate Code of Conduct through regular communication activities.
The proper functioning of the Corporate Ethics Helpline enables us to quickly detect and respond to issues such as misconduct and harassment. This minimizes risks to the Group. Promoting awareness of the system so that employees understand it correctly and improving their trust in it will provide an environment where they can report issues with peace of mind, ultimately leading to greater compliance awareness throughout the company.
Our Corporate Code of Conduct provides all Sumitomo Rubber Group officers and employees with specific, easy-to-understand guidelines regarding the basic stance they should take and the mindset they should adopt in the course of their business activities from the aspect of legal and regulatory compliance. The Code of Conduct is translated into the eight languages listed below. All versions can be accessed on the Company’s corporate website.
We expect all of Sumitomo Rubber Group officers and employees, as well as business partners who do business with the Group, to act in accordance with this Code of Conduct.
Our Group designates October each year as “Compliance and Corporate Ethics Month.” During this period, we continuously conduct various activities to ensure thorough compliance, focusing on key themes such as competition law compliance, bribery prevention, and fraud prevention. During Compliance and Corporate Ethics Month, we implement the following initiatives:
・Messages emphasizing the importance of compliance are communicated to all Group employees by department heads and presidents of each Group company.
・Employees are required to carry the Corporate Conduct Standards and Compliance Card, and their contents are reviewed and discussed.
In 2025, in addition to the above initiatives, we distributed compliance seminar materials summarizing the importance of compliance, the “Bad News First/Fast” principle, and the Corporate Ethics Helpline. We also published an article in the company newsletter to promote understanding of “Bad News First/Fast,” striving to enhance compliance awareness across the entire Group.
Furthermore, our Group has established procurement guidelines that include a comprehensive prohibition of corrupt practices such as bribery and corruption. We are advancing initiatives to ensure strict compliance throughout the entire supply chain, such as including anti-corruption clauses in contracts with suppliers and other business partners.
When launching new businesses, conducting acquisitions or mergers, or engaging agents for our Group's business activities, we perform appropriate due diligence tailored to the relevant region or country. This includes verifying the compliance status of the counterparties and agents involved.
The targets and results are as follows.
| 2025 targets |
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|---|---|
| 2025 results |
1. Disseminating messages to approximately 42,000 employees across all domestic and international locations 2. Confirming mobile access to the Corporate Conduct Standards at each location 3. Confirming viewing of compliance seminar materials at all domestic and international locations
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| 2026 targets |
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In fiscal year 2025, we confirmed the completion of initiatives for the “Compliance and Corporate Ethics Month” at all domestic and overseas locations.
The DUNLOP Group did not receive any legal sanctions, such as fines or penalties related to corruption, in fiscal year 2024. Furthermore, since 2017, there have been no cases of employee disciplinary action or dismissal resulting from violations of the Group's “Anti-Bribery Compliance Regulations.”
Previously, the establishment of external reporting channels was left to the discretion of each overseas subsidiary, resulting in inconsistent implementation across locations. However, in fiscal year 2025, we advanced the establishment of external reporting channels accessible in the native language of local staff at each overseas subsidiary. As a result, of the 14 companies that did not have an external reporting channel as of January 2025, １0 companies have completed the setup and plan to begin operations in 2026.
To further solidify a culture of promptly reporting and sharing risk information and concerns, Bad News First / Fast was re-communicated to the entire Group.
Materials and videos in both Japanese and English were prepared and distributed to all locations
Viewing of the video by all Group employees was confirmed
This has strengthened the shared understanding aimed at ensuring thorough early reporting.
In conjunction with our annual “Compliance and Corporate Ethics Month” held every October, we have expanded our educational content to deepen understanding of compliance fundamentals and its importance.
We produced materials and videos that clearly explain “What is compliance?” and “Why is it important?”
We provided detailed explanations of the Corporate Ethics Helpline (internal reporting system), including its structure, confidentiality, and how to use it, promoting an environment where employees feel comfortable seeking advice.
We confirmed that all Group employees viewed the videos.
Through these initiatives, we strengthened the foundation for employees to proactively consider and act on compliance in their daily work.
We conducted compliance seminars for select overseas subsidiaries using the following methods:
On-site face-to-face seminars / Online explanatory sessions
Topics covered included “Bad News First / Fast,” the internal whistleblowing system, and fundamental compliance principles.
The objective is to share common values and standards of conduct across the DUNLOP Group, even within diverse cultural and regulatory environments.
