Daikin's Group Conduct Guidelines state that we practice moderation in entertainment and gift exchanges. We strictly implement our corporate ethics and risk management system, which covers matters such as prohibiting bribes.
13. Practicing Moderation in Entertainment and Gift Exchanges
We shall exercise moderation and perform within the acceptable range of social norms and obey the laws and regulations of each country and region in regards to entertainment, the exchange of presents, and invitations relating to the development of our global business. In particular, we shall not entertain, provide gifts of monetary value to, or extend invitations to public officials in Japan or abroad that violate the applicable laws and regulations in each respective country and region.
In fiscal 2014, with the approval of our Board of Directors, we created our Compliance Guidelines for Preventing Bribery of Public Officials, Etc., which give detailed directives related to entertaining, gift exchanges, and invitations for government officials. These guidelines are being strictly implemented throughout the Daikin Group.
Daikin's Compliance Guidelines for Preventing Bribery of Public Officials, Etc. stipulate policies in areas such as entertainment, gift exchanges, and invitations for public officials, and outsourcing to third parties. The goal is to have standards and approval processes regarding dining and other interactions with public officials and others. The guidelines are also for preventing the dispersion of profit indirectly to public officials and others via third parties such as by hiring dealers, agents, or consultants. To this end, third party business partners are selected through a strict screening and are required to sign a contract covering anticorruption.
When there are questions regarding interpretation and application of laws and with regards to these guidelines, we have a consultation hotline in the legal department, which we constantly encourage concerned parties to make use of.
Every year, we confirm compliance with our Group Conduct Guidelines by conducting inspections through our unique self assessment system. Any compliance problems found are shared by reporting them to the Corporate Ethics and Risk Management Committee.
Daikin holds training for managers and employees so that each and every one is knowledgeable and aware of compliance with laws and company regulations. The training is conducted to ensure that employees obey rules on sound and transparent relations with government offices, are compliant with the Political Funds Control Law and the Public Offices Election Act, and conduct moderate entertainment and gift exchanges with business partners. Since guidelines were introduced in fiscal 2014, we have striven to ensure they are familiar to all employees by holding briefings for each division and group company around the world and providing e-learning for all employees of Daikin Industries, Ltd.
For employees of divisions and group companies in frequent contact with public officials, members of our legal department visit and lead periodic educational sessions.
Since formulating the Compliance Guidelines for Preventing Bribery of Public Officials, Etc., we have carried out audits in divisions and group companies that do business in countries and regions where corruption is prevalent to ensure that bribes are not occurring. Guideline-related issues discovered during the audits are dealt with by creating solutions in collaboration with relevant divisions and groups, and these are reported to the Board of Directors and the Internal Control Committee. In addition, issues and successful countermeasures are shared via the Corporate Ethics and Risk Management Committee and Global Legal and Compliance Meetings attended by compliance and risk management leaders in each worldwide region.
In fiscal 2019, bribery prevention was defined as a priority audit item by the Group Auditors Meeting. In turn, all Group companies were audited to check for compliance with this item. In particular, we conduct more detailed audits on overseas Group companies located in countries with a high risk of corruption pertaining to compliance with rules demanded of the guidelines on the use of third parties such as consultants and dealers. In addition, following a resolution by the Internal Control Committee on bribery prevention audits, the results of audits were reported to the Board of Directors.
Daikin Industries, Ltd. has a Help-Line for Corporate Ethics, through which employees can give opinions or receive consultation on all corporate ethics matters, including bribe-related issues.
In fiscal 2019, there were no incidents involving bribe-related violations or sanctions.
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