Compliance
Milbon’s Approach to Compliance
All officers and employees at the Milbon Group (including Milbon Co., Ltd. and its consolidated subsidiaries, hereinafter collectively referred to as “Milbon”) are committed to acting, throughout the value chain, in compliance with laws and regulations of all countries and regions based on high ethical standards that conform with social ethics. The Milbon Way and the Milbon Ethics and Code of Conduct have been established as guidelines that all officers and employees should always keep in the forefront of their minds in order to embody Milbon’s corporate philosophy, serving as guidelines for earning the support and trust of all stakeholders.
Milbon Ethics and Code of Conduct
Management Structure
Milbon keeps up with the laws and regulations related to its operations, its Corporate Administration Department checks the state of compliance with those laws and regulations, and reports the results to the Management Meeting and the Board of Directors as required. As laws and regulations are enacted and revised, relevant departments are informed of those details through training and other means to ensure legal compliance.
Compliance Structure
Specific Initiatives
Compliance Awareness Survey
Milbon conducts an annual survey on daily operations, workplace environment and other compliance-related items. The results of the survey are provided as feedback to the head of each division and the president of each subsidiary company. Action sheets for improvement measures are also prepared and checked to confirm whether actions have been taken.
Awareness Activities
Company-Wide Training
Milbon Co., Ltd. conducts ongoing compliance training to “create a Milbon mindset with a compliance perspective.” In 2023, e-learning courses were offered four times on trade secrets, harassment, Act against Unjustifiable Premiums and Misleading Representations, and Pharmaceuticals and Medical devices Act. Systems are in place to check attendance status and to provide refresher training.
Level-Specific and Division-Specific Training
Training and study sessions are held as required according to different job levels and division-specific characteristics.
Examples: Training for new employees, training for promoted employees, sales division training on the Law against Unjustifiable Premiums and Misleading Representations, study sessions on Antimonopoly law, study sessions on the Subcontract law, etc.
Display of Advisory Posters
Themes are selected on matters that should be kept in mind when conducting business activities, and advisory posters are created three times a year and displayed at business locations.
Examples: What to be aware of when disseminating information externally, improvement of the workplace environment, information leaks, etc.
Establishment of Contact Points for Compliance Consultation, etc.
Milbon Co., Ltd. has set up the Internal Reporting and Consultation Counter where all employees can report and consult matters of concern such as misconduct within the company. In protecting whistleblowers, the company prohibits any prejudicial treatment and ensures the confidentiality and protection of reports and their personal information. Based on the content of reports and consultation, investigations are conducted and appropriate corrective and remedial measures are taken when violations are identified. Widespread reporting and consultation is expected to lead to the early detection of any issues.
Data on compliance consultations, etc.:Sustainability-related data
Individual Policies on Compliance
Sound Relationships with Government and Administration
(The Milbon Ethics and Code of Conduct Stipulates the Following)
Milbon will maintain sound and transparent relationships with government and administration, eliminate any collusion, and act fairly. Milbon will not provide public employees with entertainment or gifts, or make “facilitation payments,” which are small payments made to public employees to expedite prescribed public procedures, with understanding of the National Public Service Ethics Act (the National Public Service Ethics Code), the Penal Code (crime of bribery), the Unfair Competition Prevention Act, as well as foreign anti-corruption regulations. When making any donations or political contributions, Milbon will comply with the Political Funds Control Act, the Public Offices Election Act, and the Unfair Competition Prevention Act, with understanding of foreign anti-corruption regulations and in accordance with the standards set forth in its internal regulations.
Basic Policy on Antisocial Forces
Milbon has established the following basic policy to resolutely reject any unreasonable demands by antisocial forces that threaten the order and safety of civil society, and to maintain public trust and ensure the appropriateness and soundness of its business operations by working to establish a system to preclude any relationships with antisocial forces.
- Organizational response
- Milbon responds to antisocial forces as an organization, without leaving it solely up to the person or department in charge.
- Cooperation with external professional organizations
- Milbon deals with antisocial forces in cooperation with external professional organizations such as the police, the Federation for the Prevention of Special Organized Crimes, and lawyers (hereinafter collectively referred to as “external professional organizations”).
- Preclusion of all relationships, including transactions, with antisocial forces
- Milbon precludes all relationships with antisocial forces and does not engage in any transactions whatsoever, whether legitimate or not and irrespective of the pretext.
- Civil and criminal legal response to emergencies
- In the event of an emergency, such as unreasonable demands by antisocial forces, Milbon actively consults with external professional organizations and takes legal action on both a civil and criminal basis.
- Prohibition of backroom deals and funding
- Milbon never engages in backroom deals or provides funds to antisocial forces for any reason whatsoever.
Basic Policy on Intellectual Property
In terms of its important intellectual property, Milbon recognizes not only patents, trademarks, copyrights and other intellectual property rights, but also trade secrets, including proprietary technologies and know-how created in the course of product development activities. In particular, the TAC Product Development System—one of the business models and the unique development know-how of Milbon Co., Ltd.—is recognized as its most important intellectual property, creating high value-added products. In addition, Milbon Co., Ltd. is constantly creating intellectual property through aggressive investment, and its dedicated intellectual property department is committed to the strict protection and appropriate management of such property. Going forward, Milbon will aim to contribute to the sustainable development of business by proposing effective utilization of intellectual property in its business strategies.
Information Security Management
Milbon views the protection of personal information as an important aspect of risk management. In 2022, Milbon Co., Ltd. revised the rules for protecting personal information and implemented an internal system. Then, in 2023, the internal rules for handling confidential information were clarified. In addition, Milbon is examining issues and implementing measures to promote more appropriate management of personal information.
