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Corporate Governance

Prohibiting Bribery and Corruption

Basic Policy and Management Structure

With the progress of a global economy, demand for anti-corruption is increasing while regulations are being tightened not only domestically but also in international business. Daikin has established its policy on "Free Competition and Fair Trading," "Practicing Moderation in Entertainment and Gift Exchanges," and "Maintaining a Firm Attitude against Anti-social Activities" in its Group Conduct Guidelines. The legal department spearheads the prevention of corruption and bribery under the supervision of the Executive Officer in charge of Corporate Ethics and Compliance.

At each division and our principal Group companies in Japan and abroad, we confirm compliance with internal rules and guidelines using self assessments*. Based on the results, each company plans and implements their own countermeasures.

Each company reports and shares the status of these initiatives with the Corporate Ethics and Risk Management Committee, with the results reported to the Internal Control Committee chaired by the President and CEO. Furthermore, the Company’s risk response is reported to the Board of Directors.

*
A unique system developed by Daikin where individual employees check their own actions pursuant to the Group Conduct Guidelines. Self assessments are conducted every year, based on which the issues of each organization are identified and compliance countermeasures taken.

Group Conduct Guidelines

2.Free Competition and Fair Trading

We shall observe all applicable laws and regulations relating to fair competition and fair trade of each country and region, including antimonopoly laws. Furthermore, we shall conduct fair sales and procurement activities based on proper corporate ethics and in accordance with sound business practices and social norms.

Specific Guidelines

  1. Observance of the Anti-Monopoly Act
    1. To ensure free competition, we shall not enter into agreements with our competitors in any country to predetermine pricing, production and sales quantity, production and sales models, business partners, sales territory, date of product launch, or similar anti-competitive action.
    2. In the case of tendered bids and quotations, we shall not enter into any agreements with our competitors to predetermine bid price or bid recipient.
    3. We shall not set the resale prices of Daikin products sold by dealers, nor shall we set the listed price in promotional campaigns or in retail stores.
    4. We shall not unfairly inhibit our dealers from selling other companies' products, nor shall we restrict their sales territories, sales routes, purchase routes, or take any similar action in violation of the Anti-Monopoly Act or other fair-trade laws.
  2. Observance of Act against Unjustifiable Premiums and Misleading Representations
    1. When indicating quality, performance, place or origin, terms and conditions and other matters related to our products and services, we shall use accurate and appropriate expressions to ensure that our products and services are not misrepresented to our customers.
    2. Any and all premiums (giveaways, discounts, etc.) given in connection with our sales transactions shall fully comply with the Act against Unjustifiable Premiums and Misleading Representations.
  3. Strict Observance of Procurement Rules and the Subcontract Act
    1. When selecting suppliers, we shall widely open our door to companies worldwide to provide fair and equal business opportunities. In addition, we shall grow together with our suppliers, maintaining friendly yet tense competitive relations so that we can develop our business together with our suppliers.
    2. We shall promote the understanding and cooperation of our suppliers in our Group to strive together in legal compliance, respect for human rights, preservation of the environment, and contribution to the development of a sustainable society.
    3. We shall strictly observe the Subcontract Act (Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors) in regard to transactions with our suppliers as we follow sound business and work to protect our business partners.

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.

Specific Guidelines

  1. Maintaining sound and transparent relationships with government and municipal offices
    1. We shall not provide entertainment, the exchange of presents, or invitations to any public servants in government offices in accordance to such laws as the National Public Service Ethics Act.
    2. In the expansion of global business, we shall not provide entertainment, the exchange of presents, or invitations to any public servants in overseas government offices that are prohibited by national or regional laws and regulations.
  2. Practicing moderation in entertainment and gift exchanges with business partners
    In regard to entertainment, the exchange of gifts, and invitations for customers or business partners, we shall comply with the laws and regulations relating to each country and region and seek moderation appropriate to the standards of society in maintaining sound business practices.

14.Maintaining a Firm Attitude against Anti-social Activities

We shall take a firm attitude against anti-social force or organization that threatens the safety and order of the citizens of society.

Specific Guidelines

  1. Prohibiting the giving of material benefits to any person regarding the exercise of shareholders'rights
    We shall not give material benefits to any person regarding the exercise of shareholder's rights.
  2. Prohibiting dealings with anti-social forces and organizations
    1. We shall have no dealings that serve as supporting or providing illegal profit to any anti-social forces or organizations.
    2. We shall not enlist the support of anti-social forces or organizations in pursuit of business activities.
  3. Instituting zero tolerance of anti-social forces and organizations
    1. We shall not meet any unjustified or unreasonable demands of any criminal groups or organizations.
    2. If contacted by an anti-social force or organization, we shall handle the matter on an organizational basis, not an individual basis. Moreover, we shall regularly work to build a specific link between law enforcement officers and outside specialists such as lawyers, and in the case of an emergency we shall take appropriate measures through both civil and criminal legal channels in cooperation with outside specialists.

Thoroughly Implementing Compliance Guidelines for Preventing Bribery of Public Officials, Etc.

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. These guidelines are always applied to companies that newly join the Daikin Group through M&A in an effort to prevent wrongdoing with regards to the guidelines Groupwide.

The guidelines 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, we have a consultation hotline in the legal department, which we constantly encourage concerned parties to make use of.

We confirm compliance with the guidelines by conducting self assessments*. Any compliance problems found and their countermeasures are shared by reporting them to the Corporate Ethics and Risk Management Committee.

Educational Activities

Daikin holds training for managers and employees so that each and every one is knowledgeable and thoroughly 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 entertainment and gift exchanges with business partners in moderation. Since the Compliance Guidelines for Preventing Bribery of Public Officials, Etc. were introduced, 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.

Monitoring

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.

Related information

Help-Line System

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 2021, there were no incidents involving bribe-related violations or sanctions.

Related information

"Help-Line" (Compliance)

Sustainability

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