Ube Industries to Strengthen Regulatory Compliance
March 11, 2003
Ube Industries, Ltd. (President: Kazumasa Tsunemi) has placed great importance on regulatory compliance with relevant standards in its management. In order to strengthen its commitment to regulatory compliance throughout the organization, on April 1, 2003 Ube Industries will launch a series of programs.
Recently, society strongly requests that companies establish and strengthen their systems for complying with regulations and standards, and the public is critical of non-compliant companies. In recognition of this social requirement, the management of Ube Industries decided to implement a further strengthening of compliance systems.
The following specific measures will be taken to promote thorough regulatory compliance with relevant regulations and proper corporate behavior.
1. Revision of Corporate Ethics
The Action Plan enacted in 1998 to be observed by all staff and directors of all group companies will be revised and strengthened in the area of compliance.
2. Management Structure to Promote Regulatory Compliance
(1) Establishment of Compliance Officers (CO)
The executive officers in charge of the General Affairs & Personnel Office and the Corporate Planning & Administration Office will be appointed as Compliance Officers (the Executive Officer in charge of the General Affairs & Personnel Office will be the Chief Compliance Officer (COO)).
(2) Establishment of Compliance Committee
Composition
| Chairman | Executive Officer in charge of the General Affairs & Personnel Office |
|---|---|
| Vice-Chairman | Executive Officer in charge of the Corporate Planning & Administration Office |
| Members | General Manager of the Planning & Accounting Dept, IR & PR Dept,
Personnel Dept, General Affairs Dept, Legal Dept, Ube Corporate Services
Dept, Environment & Safety Dept, Planning & Control Dept of Cement & Construction Materials Company, General Affairs Dept of Ube Machinery Corp., Ltd., and an outside lawyer |
Duties
The committee will gather information related to compliance and deliberate such issues as important policies, violations, and education.
(3) Establishment of Compliance Promotion Office
Duties
Under the direction and supervision of the compliance officers, the Compliance Promotion Office will promote and ensure compliance and will implement office duties related to the Compliance Committee.
3. Setting up of Direct Reporting System (UBE C-Line)
This system will ensure that compliance risks are corrected at the earliest opportunity by providing employees of the Ube Group companies with a means of reporting issues relating to violations of regulatory requirements. Under the system, employees will be able to report their concerns about actual or potential violations that they have witnessed to the compliance authorities in the company, without going through the normal chain of command.
Contact for Direct Report
Internal Contacts: Compliance Committee members, factory superintendents, General Managerof the General Affairs Dept of Ube Research Laboratory, and others
External Contact: Lawyer appointed by company
Reporting Method
Written reports by post, interviews, e-mail, Intranet communication (via exclusive screen) are among the acceptable methods of reporting.
Response
All information received in reports will be reported to the Compliance Officers, who will deliberate them with related committee members and the head of the legal department to determine the appropriate measures to be taken, such as inspection and verification.
