The EBARA Group has implemented an anti-corruption program aimed at encouraging free and fair competition, the rejection of any relations with antisocial forces, and prohibition of bribery. This program is applied to all companies in the Group and consists of 4 parts:
|1||.||A declaration made by the top executive of each group company forbidding any corrupt acts or practices by employees or the company|
|2||.||The approval of each company's Board of Directors of the Anti-Corruption Basic Policy|
|3||.||The implementation of internal regulations prohibiting any acts of corruption|
|4||.||The establishment of whistle-blowing hotlines that allow employees to anonymously blow the whistle on any activity that may be in violation of the policy or internal regulations|
|5||.||The dissemination of 1-4 to all employees|
The internal regulations define acts of corruption beyond simply bribery and also offer limitations on various types of expenses and the giving of benefits including: entertainment, gifts, travel, political or charitable donations, facilitation payments, and third-party commission fees.
The EARA Group takes disciplinary action against those who violate the anti-corruption regulations in place.
The CSR Committee, chaired by all executive officers and attended by members of the Board of Directors, receive reports on the status of the regulations and whistle-blowing hotlines. The CSR committee reports its deliberations to the Board of Directors and the Board conducts appropriate oversight.
The EBARA Group Anti-Corruption Program
President and Representative Executive Officer
28 March 2019
(English translation of original Japanese statement)
Since 2012 the EBARA Group's Anti-Corruption Program has been one of the core elements of our CSR activities. It has an important role in the implementation of our business ethics. The Program consists of 3 elements: namely, prohibition of the taking and receiving of bribes, promotion of fair and free competition, and exclusion of any ties with anti-social forces. Today, with the global expansion of the Program, we continue to monitor, evaluate, and adjust ourselves, always keeping the same original commitment against corruption.
As the President and Representative Executive Office of EBARA Corporation, I hereby renew our pledge against corruption.
|1||.||The Group’s management and employees will promote fair, faithful, and transparent business activities by complying with all laws and ordinances, as well as relevant internal policies and rules.|
|2||.||The Group will not tolerate breach of laws, ordinances, or internal policies and rules by our management and employees. Infractions will be met with strict consequences. In the event of a clear incident of corruption, the Group will suspend its business transaction with the offending external party.|
|3||.||Top management will take initiative in implementation of the Anti-Corruption Program by actively disseminating the Program and leading by example. Top management will also take responsibility when there is suspicion of corruption by ensuring proper measures are taken in the course of investigations and taking measures to prevent any recurrence.|
|4||.||The Group recognizes that trust and confidence gained from other companies, customers, business partners and stakeholders is indispensable and strives to gain that through fair, faithful and transparent business activities.|
|5||.||The Group will aim at thorough prevention of corruption, by periodically providing internal training sessions, reexamining regulations, and reviewing the state of compliance, in accordance with the Anti-Corruption Program.|
Other Activities Concerning Anti-Corruption
The EBARA Group conducts various anti-corruption activities in line with our Anti-Corruption Program.
|-||Analysis and response to risks identified through an annual compliance questionnaire|
|-||Expansion of external whistle-blowing hotlines (FY 2019 status: Expanded to all domestic group companies and 17 overseas group companies)|
|-||Anti-corruption training for overseas group companies customized for local circumstances/culture (From FY 2018, we identified 21 group companies in areas with low awareness of corruption and conducted e-learning for more than 1,600 involved with sales. In FY 2019, we expanded our anti-corruption e-learning program to 36 overseas subsidiaries and more than 2,000 employees involved with sales received training)|
|-||Surveys aimed at measuring/raising the level of anti-corruption and compliance awareness (In FY 2018, we conducted these surveys at 10 group companies in China)|
|-||Implementation of internal control self-inspection guidelines for group countries around the world concerning transactions with third-party agents/intermediaries. These guidelines include information regarding our Anti-Corruption Policy for third-party agents/intermediaries and were formulated with reference to the regulations of each country and the most current third-party management guidelines. We have been rolling them out to group companies from 2018|
In accordance with the Ebara Group Business Ethics Framework, we work to build stable relationships of trust with our suppliers as valued partners, and engage in fair and equitable transactions, in line with our procurement policy.
We request suppliers to follow our CSR procurement guidelines, as shown below.
Provide fair and equitable opportunities
We provide fair and equitable opportunities to all suppliers. To begin a business relationship with a supplier, we conduct a technological and commercial assessment using our proprietary certification system, consistent with ISO 9001. Upon completion of the certification, we enter into a basic agreement or basic work agreement and then proceed with the individual deal.
Economic rationality in selecting suppliers
When selecting suppliers, we comprehensively assess the quality of materials, reliability, delivery time, price, technological development capability, proposal capability, actions taken towards the environment, and financial soundness of the supplier.
We do not disclose to third parties any confidential information that we have acquired through our business dealings with suppliers without obtaining their approval.
We aim for mutual growth, and for building a relationship of trust and partnership with suppliers. All of the procurement section members are aware that they must maintain a good working relationship that fosters cooperation and creativity and promotes smooth and effective operational functionality with the internal and external sections concerned.
In our pursuit of a sustainable society, we promote responsible procurement, while paying close attention to compliance with Japanese and overseas laws, human rights, safety of products and services, quality guarantees, occupational health and safety, the environment, and corporate ethics.
CSR Procurement Guidelines
To our valued suppliers;
The EBARA Group will pursue mutual prosperity with suppliers by building a long term partnership through fair and equitable procurement activities. CSR (Corporate Social Responsibility) is one of the key focus areas of our corporate activities, with the aim of improving corporate value, achieving continuous growth and furthermore, creating value for society. To realize this, it is necessary for suppliers, as one of our stakeholders, to drive forward CSR activities in the same way as the EBARA Group. Therefore, we have compiled areas in which we need suppliers’ cooperation in the form of the Ebara Group CSR Procurement Guidelines below. We ask for all suppliers’ understanding and for suppliers to promote CSR activities within their own organizations. In addition, we request all suppliers to abide by this guideline.
We request strict compliance with the laws, regulations and social norms of the countries related to the transaction, in addition to the implementation of appropriate internal controls including whistle-blowing systems, in suppliers’ organizations.
2. Consideration to human rights, health and safety
We request that suppliers respect fundamental human rights by prohibiting all types of unreasonable labor (child labor, forced labor, etc) or discrimination of any type, and providing a healthy and safe working environment.
Regarding handling of conflict minerals, which have a high risk of human rights violations, you may see “Conflict Minerals Policy” below.
We also ask for suppliers’ cooperation in establishing a business continuity management system (e.g., plans/countermeasures for emergency situations, etc.) and conducting of training to prepare for emergency situations (disasters, accidents, etc.).
3. Environmental conservation
We request suppliers to continuously promote activities that reduce the impact on the global environment. Please refer to the “Ebara Group Green Procurement Guidelines” for further details.
4. Ensuring proper quality, price, delivery and safety of products and services
In order to supply satisfactory products and services to our customers, we request suppliers to provide us with products and services which are based on safe and superior quality, competitive price, reliable delivery and a stable supply system.
5. Improvement of technical capabilities
We request suppliers to continuously improve their technical capabilities.
6. Information disclosure
We request suppliers to provide and disclose information positively.
7. Information security
We request suppliers to establish a system to properly manage and protect personal and confidential information, and to prevent obtaining, using, disclosing and leaking such information illegally or unreasonably.
8. Protection of intellectual property
We request suppliers to respect intellectual property and not to infringe the intellectual property of others.
9. Corruption prevention
We request suppliers to prohibit obtrusion and bribery.
10. Dissociation from antisocial forces
We request that suppliers refuse any relationship with antisocial forces.
Conflict Minerals Policy
The environmental destruction and inhumane acts against local residents by anti-government armed groups in the Democratic Republic of the Congo and its neighboring countries have become serious international issues. Minerals such as tin, tantalum, tungsten and gold being mined in these countries have become a source of financing for the armed groups: these minerals are called “Conflict Minerals.” In responding to the call of the international community for cutting off funding sources from such armed groups, companies are now required to conduct appropriate material procurement avoiding the use of these Conflict Minerals in their products. As a member of global society, we take the issue of Conflict Minerals very seriously and address it as one of the most important CSR issues. We will implement concrete measures, with the support of our suppliers, for material procurement that will not give any advantage to the armed groups engaging in human right abuses.
Activities conducted in FY2019
The Procurement Management Committee deliberated on procurement business policies and measures to strengthen operations. The Comittee conducted the following activities in fiscal year ended December 2019 (FY2019):
・Improved procurement operations
・Introduced a supplier certification system
・Conducted CSR Procurement Questionnaire
・Responded to changes in laws and regulations
CSR Procurement Questionnaire
We administer CSR procurement surveys to suppliers to raise awareness regarding the CSR Procurement Guideline and also confirm the status of their CSR efforts.
※The questionnaire is based on the RBA Code of Conduct
In 2018 and 2019, we sent 2019 CSR Procurement Questionnaires to the suppliers that made up the top 70% of our annual domestic orders (330 suppliers). We found that 84% of respondents indicated they are conducting their business operations in line with the CSR Procurement Guideline. We provide feedback to participants and request voluntary improvements for low-scoring areas.
Supplier Physical Inspections
The EBARA Group aims to build mutual value-building partnerships with business partners to further enhance our reliability. In line with this philosophy, the Precision Machinery Business has been conducting physical inspections of supplier manufacturing facilities since FY2016. These inspections include checks regarding compliance with occupational safety and health and environmental laws and regulations, measures taken to prevent accidents, and the status of training and preparations for emergencies. After the inspection EBARA provides feedback including indicating action items. Suppliers report on the status of improvement, and EBARA provides support until we can confirm the improvements are complete. We will continue to work with our business partners to reduce operational risks.
|Number of Suppliers Inspected|
Controlling our exports is one way to manage risk on a global scale. We manage and control our exports through the following rules and systems.
We established the Rules for Security Trade Control (internal basic rules of EBARA Corporation regarding compliance to export-related laws) in 1990 and have been strictly managing such rules. The Rules have been notified to and accepted by the Ministry of Economy, Trade and Industry (METI). We formulated the Security Trade Control Manual as the detailed regulations for the Rules and manage it accordingly.
We created a department that manages and oversees security trade control, and in the domestic group, we established the EBARA Security Trade Control Committee as a cross-sectional organization and strictly manage security trade control. Through the department and committee, we communicate the latest information to the entire domestic group on regulations revised in accordance with changes in the global security environment and work on the implementation of the non-proliferation export control, a global initiative.