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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.

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