Compliance

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Fundamental Perspective

In the Sumitomo Rubber 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.”

Governance

The Group formulated the Regulations on Corporate Ethics Activities and the Sumitomo Rubber 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.

Structure of Compliance Initiatives

Structure of Compliance Initiatives

Corporate Ethics Helpline

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.

Compliance Card
Compliance card provided to all employees

Strategy, Risks, and Opportunities

In 2003, we established “Sumitomo Rubber 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.

Thorough implementation of the Corporate Code of Conduct

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.

Corporate Code of Conduct

Improving the effectiveness of the Corporate Ethics Helpline

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.

Corporate Code of Conduct

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.

Corporate Code of Conduct

Risk Management

The Group has designated October as “Legal and Corporate Ethics Compliance Month” and conducts various activities on an ongoing basis to ensure thorough compliance. During the month, we implement the following initiatives every year.
・All employees of the Sumitomo Rubber Group receive messages from their division heads and the presidents of their group companies emphasizing the importance of compliance.
・We confirm that all employees carry the Corporate Code of Conduct and compliance cards and read the content together.
・We publish articles in our internal newsletter to raise awareness of the Corporate Ethics Helpline.

In addition to the above initiatives, last year we read through the content of the Sumitomo Rubber Group Human Rights Policy established in October 2023 and the Basic Policy on Customer Harassment established in October 2024 to ensure awareness of these policies across all departments and companies.
We also confirmed the status of establishing reporting channels at overseas subsidiaries and began efforts to develop reporting channels for the entire Group.

Targets and Results

The targets and results are as follows.

2024 targets
  • Implementation of the following initiatives at all bases in Japan and overseas

    1.Dissemination of messages regarding compliance

    2.Confirmation of employees’ carrying of the Corporate Code of Conduct

    3.Reading through Human Rights Policy and Basic Policy on Customer Harassment (domestic bases only)

  • Understanding of the status of the establishment of unique reporting channels at overseas subsidiaries
2024 results

1.Dissemination of messages to approximately 39,500 employees at all bases in Japan and overseas

2.Confirmation of the employees’ carrying of the Corporate Code of Conduct at each base

3.Confirmation of reading of the human rights policy and the basic policy on customer harassment

  • Confirmation of the establishment of reporting channels at overseas subsidiaries
2025 targets
  • Continue to disseminate messages regarding compliance at all bases in Japan and overseas, and promote awareness of the Corporate Code of Conduct
  • Understanding the current status of reporting desks and improvement at overseas subsidiaries

Results evaluation and future initiatives

In fiscal 2024, we confirmed the completion of “Legal and Corporate Ethics Compliance Month” initiatives at all bases in Japan and overseas. We also ascertained the status of establishing independent reporting channels at overseas subsidiaries, which had not been accurately grasped until then. In fiscal 2025, we will gain a more detailed understanding of the actual status of the reporting system and the utilization of reporting channels. We will promote establishing reporting channels that Group employees can use in their native languages on all Group bases.

Examples of Initiatives

Formulation of Basic Policy on Customer Harassment

The Group’s Purpose is “Through innovation we will create a future of joy and well-being for all.” To “create a future of joy for all,” we listen to customer opinions and requests and pay close attention to our products and services as we conduct our daily operations.
On the other hand, we have observed behavior that constitutes harassment of our employees by some customers.
Our human rights policy includes our employees as subjects of human rights respect. “Peace of mind” outlined in our Purpose encompasses ensuring our employees’ physical and mental safety and health. We recognize that respecting the human rights of our employees and protecting them from harassment is essential for providing better products and services. Therefore, we established the Basic Policy on Customer Harassment in October 2024. We will continue providing high-quality products and services and strive to solve our customers’ issues in order to build better relationships.

Sumitomo Rubber Group Information Security Policy

The Sumitomo Rubber Group (hereinafter referred to as ‘the Group’) believes that it is important to build and maintain relationships of trust with our customers and society based on our corporate philosophy, ‘Our Philosophy.’ This policy has been formulated in accordance with our internal regulations, including the Information Security Policy and IT Security Policy, to protect the Group’s important information assets from various threats and to ensure and maintain information security. We will maintain a safe and secureenvironment by appropriately controlling the various risks associated with information assets.

1.Security Management System

Our group maintains a comprehensive information security management system by appointing an Information Security Officer and assigning responsibility for information security to specific departments based on the type of information handled. Each department is responsible for identifying information-related risks, planning and overseeing the implementation of appropriate security measures, and ensuring the effective operation of all security measures.

2.Security Measures

All employees of our group comply with laws and regulations related to information security and implement measures to ensure confidentiality, integrity, and availability to protect against various threats.
Additionally, we continuously review and update security measures in response to changes in effectiveness and business environments.

3.Establishment of Rules and Training

We classify our information assets according to their importance to ensure confidentiality, identify their location, and manage them appropriately. We also provide regular training and guidance to employees on information security initiatives and related rules to ensure the daily protection and management of corporate secrets.

4.Incident Response

In the event of an information security incident or accident, such as information leakage, unintentional information updates, destruction of information assets, system downtime, or business interruption due to the unavailability of information assets, we will promptly take appropriate measures, report the incident to relevant parties, and implement necessary responses.

5.Manufacturing Site Security

Our group evaluates security risks at manufacturing sites, taking into account safety, the environment, quality, stable supply, and other factors, and implements security measures appropriately selected based on the characteristics of manufacturing processes and equipment.

6.Product and Service Security

Our group incorporates security concepts into the development stage of products and services provided to customers and implements necessary security management even after shipment or service commencement.

7.Revision of This Policy

We will continuously review and improve this Information Security Basic Policy.
In the event of revisions, we will notify customers through posting on our website or other appropriate methods.