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: a declaration made by the top executive of each group company forbidding any corrupt acts made by employees or the company, a basic policy on anti-corruption to be adopted by each company’s board of directors, internal regulations prohibiting any acts of corruption, and the establishment of whistle-blowing hotlines that allow employees to quickly respond to any questions, concerns or notifications concerning any improper behavior.
In addition, the Ebara group takes disciplinary action against those who violate the anti-corruption regulations in place.
As of fiscal 2017, we have installed whistle-blowing hotlines at all domestic group companies, 10 overseas group companies (6 companies in China, 4 companies in Southeast Asia) and there have been no reported violations of the basic policy on anti-corruption.
The Ebara Group Anti-Corruption Program
President, Representative Executive Officer
(English translation of original Japanese statement)
Jun. 24, 2015
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 managements 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 managements 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. The 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 Measures Aimed at Anti-Corruption
The Ebara Group conducts various anti-corruption activities in line with our Anti-Corruption Program.
|-||Analysis and response to risks identified through the Compliance Questionnaire (Japanese Group Companies)|
|-||Expansion of external whistle-blowing hotlines|
|-||Anti-corruption training for overseas group companies customized for local circumstances/culture|
|-||Formulating new guidelines for group countries around the world, which take into consideration the regulations of each country and the most current third-party management guidelines|
EBARA builds stable trustworthy relationships with suppliers as valued partners, and engages in fair and equitable transactions. Our procurement policy and CSR procurement guidelines, which we request suppliers to follow, are shown below.
EBARA Group builds partnerships with suppliers (of products, materials, and services) and engages in fair and equitable transaction under the following procurement policy, which is intended to be mutually beneficial.
Provide fair and equitable opportunities
We provide open and fair opportunities to all suppliers, based on ISO9001. To start a business relationship with a supplier, we conduct a technological and commercial assessment using our certification system, which is based on ISO. Then a basic agreement or a basic work agreement is concluded, before starting to do business.
Economic rationality in selecting suppliers
In selecting suppliers, we adequately assess the quality of materials, reliability, delivery time, price, technological development capability, proposal capability and financial soundness of the supplier. Assessment criteria may differ depending on the product or on the conditions of the agreement with the customer.
We do not disclose to third parties any confidential information that we have learned 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 always maintain a good relationship with the internal and external sections concerned, and that they and the sections concerned cooperate with each other and are creative. We make efforts to allow all the operations to function smoothly and effectively.
We promote CSR 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, and corporate ethics. Furthermore, we are always thinking first of contributing to the sound development of society.
CSR Procurement Guidelines
The following CSR Procurement Guidelines summarize matters concerning what points of cooperation the Group seeks from suppliers. EBARA Group believes that, to fulfill its social responsibilities as a business and grow together with business partners, it is necessary for business partners to drive CSR activities in the same ways as the Group. Please read the below for further information.
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.
We promote environmental conservation activities in cooperation with suppliers, to pursue effective product manufacturing that takes conservation of the global environment into consideration.
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.